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1'1. Comments - Compliance <br />Below are comments on the inspection. Tide comments in:lude discussion of <br />ouservations mane during t~~e inspection. Conments also descriue any <br />enforcement actions taken during the inspection and the facts or evidence <br />supporting the enforcement action. <br />This was a complete inspection of the West Elk Mine completed by <br />Christine Johnston of the Division. Henry Austin of the Office of <br />Surface Mining was present along with Henry Barbe representing <br />Mountain Coal Company. The inspection was conducted over three <br />days; the first day consisted of checking records and the remainder <br />of the time was spent doing the site inspection. The first day was <br />cloudy and raining periodically and the other two days were clear <br />and warm. <br />AVAILABILITY OF RECORDS <br />West Elk's revised SPCC plan requires visual inspections to be done <br />annually in August. According to the operator, this inspection has <br />been completed but at the time of the Division's inspection, the <br />form contained in the SPCC plan had not been filled out. The <br />results of this inspection should be entered in this form prior to <br />the Division's next complete inspection. Pond inspections should <br />continue to be completed on a quarterly basis. The DMG permit is <br />on file and expires on July 31, 1996. The inspectors recommended <br />that annual certifications be completed on all ponds, not just the <br />oversized ponds. It was determined that proper notice had not been <br />given to surface landowners over areas to be mined; therefore, NOV <br />C-93-112 was issued. <br />SIGNS AND MARKERS <br />An additional permit boundary marker should be placed on the <br />eastern end of the loadout. The permit boundary marker on the <br />fence which faces the river should be replaced with a Mountain Coal <br />Company sign. <br />ROADS <br />There is currently a light-use road around the base of the refuse <br />pile that was constructed without Division approval; therefore, NOV <br />C-93-114 was issued. In addition, MCC has a number of light-use <br />roads that are used to access upper areas for monitoring purposes <br />that have not been included in the permit document's description of <br />light-use roads. MCC should survey the mine site for all light-use <br />roads for inclusion in the permit. Rule 1.04.111(c) defines a <br />light-use road. There are several water bars along the road used <br />to reach the upper meadow, which appear to be functional. There is <br />however, some erosion occurring on the lower reaches of this road. <br />MCC should consider regrading this road. <br />1 <br />