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III. COMMENTS - COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments also describe any enforcement actions taken during <br />the inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection conducted by Kent Gorham of CDMG. Elmer Bentley <br />represented Lorencito Coal Company (LCC) during the inspection. Ground conditions <br />were generally dry with standing water in some places in the pit area due to rain <br />on the previous afternoon. This surface operation mines coal from multiple seams <br />along a ridgeline between the Purgatoire River and Jeff Canyon on the Hill Ranch. <br />Coal is shuttled to the New Elk mine for loadout on a 15-car shuttle train. The <br />operation is currently under a temporary shutdown due to market conditions. <br />Activities at the site consist of reclamation work and monitoring. <br />Roads <br />Routing of haul road runoff at the intersection of the Jeff Canyon Haul Road No 1 <br />(JCHR No. 1) and the Lorencito Haul Road No 1 (LHR No. 1) requires improvement. <br />Sediment traps at culvert inlets along with secondary sediment control measures at <br />culvert outlets are necessary. Road runoff should be routed to culvert inlets on <br />the west side of LHR No. 1 before passing under LHR No. 1 to Lorencito Creek. <br />Generally, road surfacing appeared good. Drainage should also be improved along <br />JC HR No. 1 immediately in front of the service area. Standing water in this area <br />may result in excessive sediment production during active operations. Straw bales <br />at the office area SAE appeared to be functioning well. <br />Hydrologic Balance <br />Pond 009 held water at about 1/3 capacity. Storm event runoff did not fill the <br />pond to the lowest discharge point. Ditch D96 has been improved to promote better <br />drainage of storm flows to ditch D98 prior to entering pond. <br />Backfilling and Grading <br />Backfilling is nearing completion in preparation for temporary cessation. Wher <br />operations start up again, overburden will be hauled back from west to east <br />against remaining highwalls. If operations do not continue, material for final <br />reclamation will be hauled from Fill 8. <br />Revegetation <br />Recent rainfall has resulted in reseeded areas beginning to show sprouting of <br />grasses and annual weeds. The operator should ensure that temporarily seeded <br />areas such as topsoil piles that do not show signs of vegetation growth are <br />3 <br />