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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 />road segments in the immediate vicinity of the active South Area pit were slick, and haul <br />trucks were being pushed up-hill by scrapers. Infrequently used roads were soft and muddy <br />from melting snow. The upper end of Haul Road G was marginally passable due to soft <br />conditions, and some light use roads such as those to Sediment Ponds 009 and 015 were <br />still impassable (to full-size vehicles) due to deep snow cover in some areas. Typical spring <br />maintenance will be required along most roads within the next few weeks. Improper <br />drainage maintenance and excessive erosion was identified along a segment of the Mine <br />Entrance Haul Road/ Haul Road A near Pond 006, and a segment of Haul Road G above <br />Pond 005. NOV's CV-2003-02 and 03 were issued for these road drainage problems, and <br />details are provided under the Description of Enforcement Actions section of this report. <br />A number of specific observations or maintenance items were noted during the inspection, <br />and are listed below. <br />1) The light use road down to Sediment Pond 016, in the South Mine Area was very muddy <br />from recent melt, with runoff flow in ditches and minor rilling of the road surface along the <br />lower segment of the road. When conditions dry sufficiently to allow maintenance grading, <br />it is recommended that several water bars be installed along the lower segment of the road <br />between the switchback curve and Pond 016 inlet, to divert road surface drainage off the <br />road into the pond inlet ditch. <br />21 The lower segment of Haul Road G has previously been approved as a permanent post- <br />mining road (the segment from the county road extending to within several hundred yards <br />of the D Pit reclaimed areas). This segment will need to be modified (reduced) as discussed <br />in the permit for permanent retention haul road segments in association with final <br />reclamation of the D Pit area. <br />Bob Shevling noted during the inspection that landowners had requested that the upper <br />section of Haul Road G, extending all the way up through the D Pit reclamation area, also be <br />retained for the post-mining land use. Mr. Shevling indicated that a request to retain the <br />entire road as a permanent structure for post-mining use had been included in TR-42, which <br />is currently under review by the Division. <br />3) A small pile of coal evidently spilled from a coal truck was observed adjacent to the <br />south side of the Tie Across Haul Road, approximately Y< mile west of the 20 Mile County <br />Road. The coal needs to be cleaned up. <br />Hvdroloaic Balance <br />Snowmelt runoff was in progress within almost all mine areas. In drainage basins with a <br />high percentage of disturbed and reclaimed ground, runoff from snowmelt may have been at <br />or near the peak. Runoff appeared to be at an early stage in drainage basins with a high <br />percentage of native aspen and tall shrub habitat (such as the upper Sage Creek <br />watersheds). Disturbed area drainage within the various disturbance areas was being <br />6 <br />