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Page 4 <br />August 20, 1998 <br />Mr. Michael B. Long <br />Potential for damage to road structures due to runoff in excess of the design event is recognized <br />within the Regulations. Rule 4, Section 4.03.2(6)(c) addresses maintenance following a <br />catastrophic event. It allows a practicable amount of time to repair such damage. <br />Inspection and action taken: <br />Mr. Dan Mathews arrived for a normal complete inspection on Tuesday, August 4 at about 9 <br />a.m. I apprised him of the situation at the East Portal Area. We then proceeded to inspect the <br />East Portal Area first. Upon inspection Mr. Mathews felt that the maintenance of these culverts <br />should take top priority. He informed me that he would issue a NOV if these two culverts were <br />not cleaned by the time he completed his inspection. <br />Afrer leaving the East Portal Area we proceeded to the mine offices at the D Portal Area and met <br />with Mr. Rick Brady, Surface Superintendent, to brief him on Mr. Mathews' request. Mr. Brady, <br />in-tum, immediately contacted Mr. Glen Filener, Surface Forman, and instructed him to contact <br />me to get additional instructions as to what needed to be done at the East Portal. <br />Mr. Mathews and 1 met up with Mr. Filener shortly thereafrer in route to the Refuse Area. Mr. <br />Filener was apprised of the situation and immediately proceeded to making arrangements to <br />expedite the task at hand. <br />To clear the culverts a backhoe and pressurized water truck were required. BME's backhoe was <br />doing maintenance 18 miles away on a remote section of BME's railroad line to the power plant. <br />Thus, a backhoe had to be rented. Since BME's water truck was not set up to provide <br />pressurized water a water truck was contracted to flush out the culverts. <br />The necessary equipment arrived the following morning and work proceeded on CMP #4. CMP <br />#4 was presumed to be the most difficult culvert of the two to clean. The sump was dug out at <br />the upper end of the culvert. Water was injected through a pipe inserted into the lower end in the <br />attempt to clear the blockage. Initially progress was being made by the flushing efforts. <br />However, progress had slowed considerably at clearing the blockage that afrernoon. <br />The backhoe was then used to uncover a middle portion of CMP #4 to allow inspection. The <br />culvert at this point was partially blocked with rock fragments and sediment generated from the <br />slope above the culvert. It was decided to continue flushing attempts on the culvert using the <br />freshly uncovered section for access. Additional flushing proved non-productive. The flushing <br />continued until midnight with no noteworthy progress. <br />Shortly afrer 6 a.m. the following morning work to cleaz the blockage recommenced. An <br />inspection hole was dug close to the upper end of CMP #4. At this point the culvert was totally <br />blocked with mud and rock. Based on BME's previous efforts it was decided to completely <br />replace the 120 feet of culvert. <br />