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Edna 4/93 page 3 My position on the violations at the site is that the root cause of most of the violations is a lack of drainage planning and design. The NOVs listed above will require P&M to develop drainage plans and designs for those areas that had the most problems; the areas without detailed drainage designs. Those areas are the Goat Trail road, the shop/warehouse/fuel pump locations, and the explosives area. Listed below are the individual locations that are in violation. Compliance with the NOV's should address all of the locations. Tipple CMP TA-8 was clogged. Drainage was routed to the pond prior to the end of the inspection at this location. CMP TA-6 had drainage going around the headwall rather than through the CMP. This was also fixed prior to the end of the inspection. Blocked CMP at the rapid (?) loadout. Goat Trail Road and Conveyor Eroded outlet at the 1st CMP north of the 1st switchback. There was also a gully from road drainage on the same slope about 25 feet from this CMP. Eroded ditch on south side of the conveyor from Transfer C down to the end. Spilled coal around the conveyor and where it had washed onto the vegetated a~ ea. Filled in drainage ditch at the 3rd switchback. This has caused the runoff to drain down the road. Eroded outlet and clogged inlet on the CMP at Transfer AB. Eroded ditch relief downdrain at the 2nd switchback from the top. This is designed to have hay bales placed at the top. The hay bales were not in place and, even if in place, the bales would not do anything for the slope on which the ditch outlets. Gully from road drainage on outslope about 50 yards below Transfer A. No detailed drainage designs. The road was inadequately surfaced. Even a 4-wheel drive had problems keeping traction. Shop/Warehouse/Associated Areas Coal and surface material has been pushed onto the east side outslope and into the oak brush during snow removal operations. The north end of the storage yard drains through a slot cut to the east and to the tipple ponds. No drainage designs for this area other than watershed breaks. Small breech through the road berm on the east side of the office. CMP E-12 blocked. Ditch from CMP E-12 to the explosives area is full of what appears to have been some sort of mud flow. The roads were inadequately surfaced. Mud was over the foot of my boots in places. Explosives Area No detailed drainage designs for this area. CMP in northwest corner of the pad has an eroded outlet.