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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. Field inspection was conducted on 3/19 and the morning of 3/20; office <br /> records were checked on the afternoon of 3/20. Tonya Hammond, SCC owner representative, was contacted on <br /> site during the field inspection on 3/19, however Ms. Hammond did not accompany me during the inspection. <br /> Jim Stover was contacted at J.E Stover&Associates offices on the afternoon of 3/20, during the records check. <br /> The South Portal reclamation project has been largely completed. The seeding contractor(WD Yards)was on- <br /> site on 3/19, hydro-seeding and hydro-mulching the Access Road 1A fill slopes and Sediment Pond 8 areas. <br /> The 4"ADS pipe extending out of the sealed South Portal (and through the highwall backfill) had recently been <br /> plugged with pumped concrete grout. A small discharge(approximately 1-2 gpm)of water was leaking from the <br /> plugged pipe;further measures appear to be warranted to seal the pipe, and the operator has indicated that an <br /> amended sealing plan will be submitted shortly. <br /> Weather during the inspection was clear and mild. There had been no appreciable precipitation recently, and <br /> the entire site was free of snow. <br /> Availability of Records <br /> Required records were on file and up-to-date through the 4th 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 /> APCD Air Pollution Emission Notices for various permit locations included in Permit Appendix 16-1 appear to <br /> have expired. However, operator had documentation of timely renewal applications on file. APCD personnel <br /> had indicated to Ms. Hammond by voice mail that renewed APEN notices were not required. <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 2-West Portals, the gullied water bar outlet located along the short road segment between the two <br /> reclaimed portal locations had been graded and rocked subsequent to the November inspection. The <br /> water bar itself was largely worn down and needs to be built up. <br /> • The water bar on the North Decline Access Road northeast of Pond 7 needs to be reestablished. <br /> • In the UTL area,the 12" CMP culvert on the north branch of Haul Road 3, approximately 200-300 <br /> feet north of the new construction soil stockpile was partially blocked, and requires cleanout. <br /> Construction of new Access Road 1A has been completed. The road has been gravel surfaced, the drainage <br /> ditch riprapped, and slopes above and below the road have been seeded and mulched. Slopes above the road <br /> (the old Access Road 1 alignment)were roughened, seeded, and hydro-mulched in February; slopes below the <br /> road surface were roughened, seeded and hydro-mulched following ground thaw in March (seeding completed <br /> on 3/19). Because the road will be a permanent structure that will remain in place following sediment <br /> pond removal, P.E. construction certification will need to be provided. <br /> 3 <br />