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III. 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 inspection <br /> and the facts or evidence supporting the enforcement action. <br /> General Comments <br /> This was a complete quarterly inspection of the mine site and office records, conducted by Dan Mathews of the <br /> DRMS Grand Junction Field Office. Tonya Hammond, SCC owner representative, was contacted on site during <br /> the field inspection on 11/27, and at J.E Stover&Associates offices on 11/28 during the records check. <br /> Reclamation work was continuing at the South Portals Area, along with associated fill excavation at the rail <br /> loadout and haulage to the South Portal site. Earthwork is projected to be completed by around the end of the <br /> year, with seedbed preparation and seeding to be conducted immediately thereafter. <br /> Weather during the inspection was clear and cool. There has been no appreciable precipitation in recent weeks. <br /> Availability of Records <br /> Required records were on file and up-to-date through the 3rd Qtr., 2007. Records on file include air quality <br /> permits issued to Halliburton in November/December 2006 for rail off-loading activities at the unit train loadout, <br /> as well as a Minor Site Plan Modification issued by Mesa County Department of Planning and Economic <br /> Development on 8/9/06, allowing for the rail off-loading and material storage activities specified in the DRMS <br /> permit. Minor Site Plan Modification associated with use and modification of South Portal structures for the <br /> commercial postmining land use approved in PR-3 was previously incorporated into the approved permit. <br /> Roads <br /> Permitted roads and associated structures have generally been maintained in satisfactory condition; however a <br /> few minor drainage problems were evident. <br /> At the upper dip section crossing of Coal Creek, minor erosion has initiated along the southeast corner <br /> of the concrete structure, and repair is warranted. <br /> A water bar outlet on the short segment of light use road between the two reclaimed portal locations at <br /> the 2-West Portals has eroded a short gully down the outslope; grading and riprap installation is <br /> warranted. <br /> The water bar on the North Decline Access Road northeast of Pond 7 needs to be reestablished. <br /> Straw bales need to be replaced at the Coal Creek Lower Dip Section Crossing. <br /> The light use road segment above the RSRDA soil borrow area was reclaimed (graded, seeded and mulched) in <br /> August. The lower segment of this light use road (between the soil borrow area and the top of the RSRDA <br /> disposal area)was graded and roughened in August/September, and was seeded and mulched earlier in <br /> November, with the exception of a segment above the RSRDA that will be seeded and mulched in association <br /> with the main South Portals Area reclamation project, in December or January. <br /> Construction of the new Access Road 1A at the South Portals is nearing completion, although final surfacing and <br /> drainage installation is not yet completed. P.E. Certification of the road will be required following completion of <br /> construction. Access Road 1 from the lower facilities area to the upper bench is still in place; reclamation of this <br /> road segment will be initiated shortly. The Access Road 1 segment to be reclaimed is being replaced by new <br /> Access Road 1 A. <br /> 3 <br />