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~'^~•Ti <br />r. ` ,t -,.~ `~. <br />Ill. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a joint OSM/DMG "special focus" inspection of the three <br />existing coal waste disposal areas at the Roadside Mine, including <br />the Roadside Refuse Disposal Area (RSRDA), Cameo Refuse Disposal . <br />Area No. 1 (CRDA-1), and Cameo Refuse Disposal Area No. 2 (CRDA-2). <br />The inspection was conducted on August 5, and August 6, 1997 by Dan " <br />Mathews of DMG and Glen Golden and Ron Sassaman of OSM. A follow- <br />up site inspection was made by Dan Mathews on August 8, in <br />conjunction with Joe Gumber and Jim Miller of the Colorado Division <br />of Wildlife (DOW), to discuss DOW's request that final reclamation <br />of refuse area slopes and other reclaimed areas incorporate <br />replacement of surface rock for small animal habitat. Larry <br />Reschke of Powderhorn Coal Company (PCC) was present during each <br />day of the inspection. <br />The special focus inspection involved review of records associated <br />with the refuse areas, including quarterly operator inspection <br />reports/construction certifications, compaction reports, piezometer <br />monitoring records, stability analyses, and DMG refuse cover <br />replacement documentation. Historical records were reviewed at the <br />DMG mine offices, previous quarter records were reviewed at the PCC <br />mine office. <br />Field inspection included general assessment of active operations <br />and reclaimed slopes at each refuse area, with respect to permit <br />compliance, apparent stability, excessive erosion, vegetation <br />establishment, and maintenance of surface water drainage controls. <br />In addition, field measurements using an abney level, 300 foot <br />tape, and tape measure were made to check apparent compliance with <br />permit specifications for final reclaim slope gradients; terrace <br />drain spacing, slope and dimension; diversion/collection ditch <br />dimension, shape, and gradient; and culvert sizing. <br />Records Review <br />Review of quarterly stability inspections revealed that a report <br />addressing underdrain construction for CRDA-1, pursuant to Rule <br />4.09.1(11)(a) and (c), was not on file at DMG or PCC offices. <br />Underdrain construction occurred in 1981 or 1982,. while the <br />earliest stability inspection on file was from 1984. Archived DMG <br />and OSM inspection reports from the time period in question will be <br />reviewed to determine if the reports contain documentation of <br />compliance with underdrain construction specifications. The <br />southern most underdrain outlet is visible adjacent to the Pond 6 <br />inlet ditch, and appears to be functioning effectively, with <br />seepage water generally present. <br />