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<br />III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />General Comments <br />This was a complete quarterly inspection of the mine site and office records, conducted by Dan Mathews of the <br />DRMS Grand Junction Field Office. Tonya Hammond, SCC owner representative, was present during portions <br />of the field inspection. Reclamation work including structural demolition and French drain installation (as <br />recently approved by PR-3) was underway at the South Portals Area, and grading work associated with rail off- <br />loading had been initiated at the unit train loadout. <br />Weather during the inspection was clear and cool. Surtace soils were moist to muddy due to recent rains. <br />Operator reported 1.2" of rain at the site on Sunday, 9/23, and 0.88" the previous Sunday. Winter annuals such <br />as cheatgrass had recently germinated in some locations. <br />Availabilitv of Records <br />Required records were on file and up-to-date through the 2nd Qtr., 2007. Records on file include air quality <br />permits issued to Halliburton in November/December 2006 for rail off-loading activities at the unit train loadout, <br />as well as a Minor Site Plan Modification issued by Mesa County Department of Planning and Economic <br />Development on 8/9/06, allowing for the rail off-loading and material storage activities specified in the DRMS <br />permit. Minor Site Plan Modification associated with use and modification of South Portal structures for the <br />commercial postmining land use approved in PR-3 was previously incorporated into the approved permit. <br />Roads <br />Permitted roads and associated structures have generally been maintained in satisfactory condition; however a <br />few minor drainage problems were evident, resulting from the recent heavy rains. Along Coal Creek, the major <br />haul road culverted crossings including the dip sections were in good condition and had recently been <br />maintained. The diversion dip/water bar located a short distance to the west of the upper dip section <br />crossing has been worn down and needs to be better defined. <br />A water bar outlet on the short segment of light use road between the two reclaimed portal locations at <br />the 2-West Portals has eroded a short gully down the outslope; grading and riprap installation is <br />warranted. <br />The light use road segment above the RSRDA soil borrow area was reclaimed (graded, seeded and mulched) in <br />August. The lower segment of this light use road (between the soil borrow area and the top of the RSRDA <br />disposal area) has been graded and roughened, but has not yet been seeded. The graded area will be seeded <br />and mulched this fall. <br />There was some down-cutting along the road ditch on the upper segment of Access Road 1, between the South <br />Portal bench and the top of the RSRDA. The ditch segment will need to be graded and riprapped as <br />warranted to prevent erosion, in conjunction with the South Portals reclamation project currently in <br />progress. <br />Hvdrolocic Balance <br />Drainage and sediment control structures were in general properly maintained and functional. Silt fencing and <br />berms at the various small area exemption sites were for the most part intact and functional, however <br />maintenance is necessary to repair or replace several silt fence installations at the South Fan site, which <br />had been damaged by runoff over the past weekend. Also, silt fences at the 2-West Portals reclaimed <br />substation area are worn and need to be replaced. <br />3 <br />