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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 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 partial monthly inspection of the surface facility areas at the McClane Canyon Mine. <br />The inspection was conducted by Dan Mathews of the DMG Grand Junction Field Office, <br />accompanied by operator representative Rodney Head. Weather was clear and warm, surface <br />soils were moist from recent precipitation. <br />One enforcement action (NOV CV-2005-008) was issued based on this inspection. The NOV and <br />associated facts and observations are described below. <br />NOV CV-2005-008 <br />CV-2005-008 was issued for "Failure to maintain upland diversion culverts and a haul road culvert <br />in accordance with approved designs and applicable performance standards". <br />The subject locations included the inlet of 42" upland diversion culvert "D", inlet of 18" upland <br />culvert "E", and inlet of 42" haul road culvert "H". Culvert "D" conveys undisturbed drainage from <br />large watershed C-3 to a diversion culvert buried beneath the mine bench facility area. Culvert <br />"E" conveys undisturbed drainage from a smaller watershed C-4, and ties into the same buried <br />diversion culvert as Culvert "D". Culvert "H" is located downstream of the mine bench facility area <br />on McClane Creek, downstream of the outlet of the buried diversion culvert. Culvert "H" routes <br />the flow of McClane Creek (an ephemeral stream) beneath a large haul road fill constructed <br />across the drainage. <br />At the time of the inspection, Culvert "D", a drop inlet with a large CMP riser structure attached, <br />was approximately''/z blocked by sediment at the inlet (see digital images 2267 and 2269). The <br />inlets of Culverts "E" and "H" were completely buried by sediment. Digital image 2265 shows a <br />segment of Culvert "E", the associated concrete inlet headwall, and the eroded slope adjacent to <br />the culvert. Digital image 2266 shows the sediment deposition at the Culvert "E" inlet, level with <br />the top of the concrete headwall. Image 2273 shows the Culvert "H" headwall; the inlet itself is <br />completely buried by sediment. Image 2275 is the outlet of Culvert "H", at the downstream foe of <br />the haul road fll across McClane Creek. <br />All of the various small natural tlrainages and ditches in the mine area showed evidence of <br />significant recent flow. Operator indicated that there had been rain at the site on the night of <br />October 18, and the rain gage at the mine office recorded % inch of precipitation. It was apparent <br />that some drainage maintenance and grading had been performed in the mine bench area <br />subsequent to the storm, notably in the immediate vicinity of upland diversion culvert "A", and <br />along the base of the cut slope behind the shop facility. Also, there appeared to have been some <br />sediment excavation from the sump area in the immediate vicinity of the Culvert D riser structure. <br />However, work had not been initiated to clean out the partially blocked inlet of Culvert "D", or to <br />excavate and restore the design functionality of Culverts "E" and "H". Rodney Head indicated <br />that he was not aware that the three culverts had been blocked by sediment resulting from the <br />storm event. Mine Manager Walter Whitledge was not present during the inspection; he had <br />apparently been in Kentucky on business and personal matters since prior to the storm. <br />