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III. Comments - Compliance <br />Below are comments on the inspection. The comments include discussion of <br />ooservations made during the inspection. Comments also describe any <br />enforcement actions taken during the inspection and the facts or evidence <br />supporting the enforcement action. <br />inlet to this culvert was plugged with mud. Road ditches showed signs <br />of erosion and sedimentation. An attempt was made to reference the <br />culvert, culvert outlet, and ditch designs in the permit application, <br />but there were no approved designs. NOV C-93-025 was written for a <br />failure to include a description and design for each existing structure <br />For which there are specific designs required. Switchbacks on the road <br />at road water release points also were causing severe erosion. An 11' <br />deep gully had formed at the road switchback in the vicinity of <br />Conveyor Transfer Point A/B, causing uprooting and damage to stands of <br />Oak Brush. Road drainage at the second switchback down from the shop <br />had formed a gully 8' deep. The approved permit application requires <br />straw bale filters at road switchbacks to minimize erosion and <br />siltation. No straw bales were in place. NOV C-93-024 was issued for <br />failure to maintain the road to prevent erosion and siltation. NOV C- <br />93-026 was issued for failure to retain sediment within disturbed areas <br />and minimize erosion to provide protection for topsoil and vegetation. <br />NOV C-93-027 was issued for failure to construct and maintain sediment <br />control measures as designed. <br />The North Access Road was inspected and no problems were noted. The <br />road should, however, be reclassified as a haul road since lump coal is <br />transported from the grizzly pad to the lump coal storage and loading <br />area over this road. The operator should submit a technical revision <br />to change the status of the road within thirty days. <br />Skyline Drive was inspected, and no problems were noted. The operator <br />discussed plans to relocate a portion of the road. P&.M has tentatively <br />agreed to perform earthwork to cover the Routt County Landfill, which <br />is located along the western permit boundary. Cover for the fill would <br />be taken from Skyline Drive, and the road located over the fill. The <br />operator will be submitting a technical revision application for the <br />project in the near future. <br />Access and haul roads in the West and Center Ridge areas were inspected <br />and showed no apparent problems. <br />HvdroloEic Balance - The tipple pond series all held water and were <br />discharging. Each of the ponds had a visible oil sheen. The second <br />and third ponds appeared to have a considerable amount of oil present <br />in the surrounding earth, which may have been residual from the May <br />1992 waste oil spill at the tipple. Tipple Pond #4 was discharging at <br />a rate of 1-2 gpm, and a sample was taken to be analyzed for oil and <br />grease content. There was a visible sheen on the sample taken. Field <br />parameters were not recorded. The operator declined a sample split <br />since he had sampled the pond earlier in the day (3/31/93). The CDMG <br />Edna Strip Mine 2 3/30/93 - 4/2/93 <br />