2003-06-10_INSPECTION - C1981038

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III. COMMENTS • COMPLIANCE - -- - - Below are comments on the inspection. The comments Include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. . West Mine -Portal Bench The inspection began at the West Mine portal bench, where BRL had requested bond release for structural demolition and backfilling and grading work. Although the entire West Mine portal bench azea was backfilled and graded, only the upper azea is included in the bond release request. The upper area includes the backfiiled and grad:'d portal bench and the backfilled and graded haul road leading from the portal bench to the public road. The lower area contains the two sedimentation ponds and the underlying East Roatcap Creek culvert. Once the remaining upper azea has enough vegetative cover to stabilize erosion, additional reclamation work will be performed at the lower azea. This additional work includes the removal of the East Roatcap Creek culvert and the two sediment ponds and additional backfilling and grading work to achieve approximate original contour. All superstructures were demolished and removed for salvage from the West Mine portal bench azea. These superstructures included the shop building, rock dust bin, substation, fuel station and motor control facilities. The associated concrete footings, slabs, walls and floors were broken up and buried in placed with more than four feet of cover. The three portal adits were sealed with concrete block seals placed 150 feet in from the adit entrance and then backfilled with 150 feet of compacted non-combustible material. BRL has not responded yet to the Division's request for documentation of the Mine Safety and Health Administration (MSHA) inspection of the portal sealing project. BRL reestablished the section of the East Roatcap Creek light use road that was eliminated by the construction of the West Mine portal bench. The light use road is located on the east side of East Roatcap Creek. In the Division's adequacy review letter dated January 6, 2003, the Division requested documentation of the slope stability factor of safety for the backfilled and graded area at the West Mine portal bench: The Division has not received this engineering demonstration yet, although the Division does have some of the compaction data for the site. During the'field inspection, the as-built contour map provided by BRL in the submittal dated November 5, 2002 was compared to the approved reclamation contour map, Sheet 9 of 10 of the Golder Associates report found in Volume 6A of the permit application. The latter map also showed the pre-mining contours of the disturbed azea. This comparison showed that the as-built contours and cross-sections of the backfilled and graded azea closely resemble the contours and cross-sections presented in the approved