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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made _- <br />during the inspection. Comments alsc.describe any enforcement actions taken during the inspection -- <br />and the facts or evidence supporting the enforcement action. <br />This was a partial inspection of the Yoast Mine conducted on July 18, 2002 by Mike Boulay of <br />the DMG. Lori Smith of Seneca Coal Company (SCC) was present during the inspection. Dan <br />Allen was present during a portion of the inspection in the Yoast South area. Weather conditions <br />were clear and warm. Ground conditions were dry throughout the majority of the site. Coal was <br />not being hauled from the mine at the time of the inspection, and the dragline was down for <br />repairs in the Yoast South area. Backfill and grading operations are underway in the Neck Pit <br />azea and at the eastern end of the Valora Pit. Water trucks were being utilized for dust control <br />purposes on Haul Roads A and B during the inspection. <br />Hydrologic Balance <br />Several culverts require maintenance or replacement to ensure that they function properly and <br />continue to convey the design flow . Culvert YB-6 located beneath the road crossing at Armand <br />Draw is partially plugged with sediment at the outlet. SCC may consider excavating below the <br />Culvert YB-6 outlet and improving the channel at this location, to reduce sediment accumulation <br />in and below the outlet. The inlet to Culvert D-4 is crushed and entirely buried with sediment <br />and should be replaced. SCC has indicated that they will replace Culvert D-4. Culvert YB-1 <br />located south of Pond 010 is completely plugged with sediment on the outlet side. In accordance <br />with Rule 4.03.1(4)(e), culverts shall be constructed to avoid plugging or collapse and erosion at <br />the inlets and outlets. Culverts shall also be designed to promote conveyance of the design flow. <br />Please make the necessary repairs and/or replacement of these culverts. <br />Topsoil <br />Topsoil redistribution is still in progress in the North Pit azea. Topsoil was redistributed on <br />approximately 35 acres in the North Pit azea during the previous month. <br />Topsoil Stockpile Q is located very close to the disturbance boundary in the Yoast South azea. <br />Dan Allen of SCC accompanied the DMG on an inspection of the topsoil stockpile. A GPS unit <br />was utilized to locate the surveyed disturbance boundary line in relation to the edge of the topsoil <br />stockpile. Based on the survey information it was determined that an adequate buffer zone had <br />been maintained azound the south and west sides of the topsoil stockpile. A berm should be <br />constructed azound the topsoil stockpile to protect the resource from erosion and to control runoff <br />from the pile. To ensure compliance, please continue to maintain an adequate buffer zone <br />between disturbed and undisturbed ground at all active mining azeas throughout the mine site. <br />