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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 <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection conducted by Janet Binns of CDMG. <br />Mr. George Patterson of Kerr Coal Company accompanied the <br />inspection. Weather was partly cloudy. Two to six inches of snow <br />covered the mine site. The mine site was mostly frozen and not <br />muddy. <br />Roads: Haul roads A and B have been reduced in width to light use <br />roads as approved in MR-25. Light use road A has been permitted as <br />a permanent road, while light use road B is approved as a temporary <br />road to provide access to pond G. Both roads have been reduced in <br />width and topsoil reapplied to the "buffer" areas adjacent to the <br />roadways. MR-25 called for a road width of 20 feet. The operator <br />has found that a wider road width is necessary and plans to 'revise <br />the proposed road width of light use road A. <br />At the time of the inspection, a cover crop of winter rye was being <br />seeded in the reclaimed portion of former haul road B. Topsoil <br />depth was verified at this reclaimed portion of road adjacent to <br />light use road B (see Topsoil section of this report). The <br />operator reported that the cover crop (Winter rye) had been seeded <br />in the reclaimed "buffer" area adjacent to light use road A as <br />well. <br />The roadway surface of light use road A was dry and in good repair. <br />Culverts 2 and 3 have not been reduced in length yet in accordance <br />with the narrower roadway. Culverts 8 and 9C remain in Bush draw. <br />Culvert 9 has been removed. <br />Hydrologic Balance: Post-mining designs for PD-1 and PD-2 were <br />approved in TR-16. Both PD-1 and PD-2 were snow covered. Steep <br />sections in both PD-1 and PD-2 have Enkamat lining anchored with <br />wooden stakes. PD-1 and 2 have been constructed in compliance with <br />the designs. <br />SAE located on the west ridge of Pit 1 was inspected. This SAE was <br />approved in MR-28. The silt fence has been keyed in and has a rock <br />filter approximately 8-10 foot wide spanning the Swale. The <br />operator reported that cuts have been made in the woven filter <br />fabric in the location of the rock filter to allow flow through the <br />rock filter. A larger rock size was utilized than originally <br />planned: D50 is estimated to be 1-4 inch dia. cobbles. The height <br />of the rock filter is approximately 18 inches. Additional felting <br />type filter fence has been installed upslope of the woven filter <br />fence. The ditch on the west side of the topsoil windrow area is <br />intact. The windrowed topsoil piles have been redistributed on the <br />regraded pit 1 area. <br />U <br />