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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 />This was a partial inspection conducted by Kent Gorham of the Colorado Division of Minerals <br />and Geology. This site is temporarily inactive due to the shutdown of the sister operation <br />Lorencito Canyon, #C-96-084. The weather was cool and unsettled. The snow covered <br />most of the ground due to a recent storm. Ground conditions were very wet and muddy <br />underneath the snow cover. Bobby Steele of Lorencito Coal Company accompanied me on <br />April 6~h <br />Roads <br />All roads were found snow covered and muddy. The light use road from the prep plant to <br />pond 7 was extremely muddy and rutted due to drainage flowing onto the surface of the road <br />from the clean coal stockpile. Most of this flow was coming down the constructed ramp to <br />the south of the road. When conditions allow, all roads will likely need to be graded to <br />restore drainage and eliminate ruts. Since the site is no longer operational, the clean coal <br />ramp could be eliminated. The access road to the RDA was also very muddy and some <br />erosion was noted due to recent runoff. Culverts under the road were functional and <br />observed flowing due to snowmelt. <br />Hydrologic Balance <br />The western most containment at the West Mine was snow-covered but dry. The <br />containment next to the topsoil borrow area was about 1/3 full of water. Pond 7 at the far <br />east end of the mine site was filling due to runoff but the high water line was still 100 feet <br />west of the bottom of the primary riser. The gate on the outlet was observed closed, in <br />accordance with the operator's commitment to operate the pond manually to improve <br />function. The sediment marker in pond 7 has fallen over and should be re-installed when <br />conditions allow. The three containments at the RDA all held water, with the SE containment <br />noted as nearly full. As mentioned last month, the two south containments should be <br />considered candidates for cleaning this season. <br />Pond 8 at the RDA was filling on April 5~" due to snowmelt. The water level was about 1 foot <br />below the top of the drop inlet riser. On April 6~h, flow continued off the RDA and the pond <br />level was observed about 6 inches from the top of the riser. On the afternoon of the 7~h, the <br />pond was observed discharging through the primary riser. No flow was noted through the <br />emergency spillway. The discharge was murky but appeared to be comprised of suspended <br />material. Due to a backwater immediately downstream of the v-notch weir box, the flow <br />depth should not be determined. However, a scratch was made on the weir box so that flow <br />depth could be determined following cessation of discharge. The flow was observed entering <br />the concrete emergency spillway downstream of the embankment, where it proceeds to the <br />south through culverts under Highway 12. A small hole in the emergency spillway where the <br />primary spillway flows enter should be repaired as soon as possible to prevent any future <br />flows from undercutting the concrete spillway. The operator should endeavor to sample <br />discharge as necessary and as required by the approved CDPS permit. <br />3 <br />