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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 /> French drain installation in the immediate highwall backfill area at the South Portal was previously completed, <br /> and appears to be functioning properly in draining away seep flows that originate in the vicinity of the backfilled <br /> portal openings. Discharge from the French drain is evident at the culvert outlet below Road 1A, into the <br /> RSRDA North Side Collection Ditch. The discharge is a pulsed flow, approximately 5gpm or less. The 001 <br /> discharge dewatering pipe (which extends out through the highwall backfill) had recently been sealed with <br /> pumped concrete grout, pursuant to the approved plan. Unfortunately, the grout did not completely plug the <br /> pipe;there was a flow estimated at 1-2 gpm out of the sealed pipe at the time of my inspection. Presently, the <br /> flow from the 001 discharge pipe is drained away from the highwall backfill via the French Drain, and the 001 <br /> leakage makes up a portion of the small flow into Pond 8. A remedial plan to permanently plug the <br /> discharge pipe will need to be submitted within a technical revision application by May 1, 2008. <br /> The 016 mine discharge site near the North Decline area, was flowing at approximately 280 gpm (typical), flow <br /> was clear. <br /> Backfilling and Gradinq <br /> The various backfilled and graded areas were walked, and in general slopes appeared to be stable, with no <br /> excessive erosion, slumping, or other indications of instability. <br /> The operator had recently repaired two small "sink hole"type features at the North Portal reclaimed area, <br /> overlying the backfilled portal decline. Operator reported the holes to have been 6 to 8 feet deep, apparently <br /> caused by soil settling in the vicinity of a couple of buried boulders. The boulders were excavated and the <br /> openings filled in and compacted. A similar feature had developed, and had been similarly repaired, in the <br /> central portion of the"floor"of the CBA-2 soil borrow area. The old "Pre-Law" Cameo mine workings extend <br /> beneath the borrow location, and it is possible that the opening was caused by subsidence associated with the <br /> pre-law workings. These locations will need to be checked periodically during the liability period. Areas <br /> disturbed by repair activity will need to be seeded, and the fence that was taken down to allow <br /> equipment access to the CBA-2 area will need to be repaired. <br /> Backfilling and grading associated with the South Portals reclamation project has been largely completed, and in <br /> general looks quite good. One problem area was noted along the upper bench outslope. Salt staining along the <br /> berm on top of the outer edge of the bench indicates that runoff water had ponded along the berm, and staining <br /> on the outslope below indicates that there was seepage from the areas of ponding that emerged on the slope. In <br /> one location, there appears to have been piping erosion and concentrated flow that caused a gully to form on the <br /> slope. The gully will need to be filled in and seeded,and additional grading or other appropriate <br /> measures will need to be taken to establish positive grade along the top of the bench to eliminate <br /> ponding, and ensure that runoff is routed to appropriate ditch, culvert, or down-drain locations. <br /> Processinq Waste <br /> Most areas of the CRDA-1 and RSRDA waste disposal sites site were walked, and the reclaimed CRDA-2 was <br /> viewed from the top of CRDA-1. There were no indications of instability or excessive erosion. Diversions, <br /> perimeter ditches, and terrace drains appeared to be properly maintained and functional. <br /> On CRDA-1, there has been some recent disposal of coal waste from the South Mine area on the open portion <br /> of the pile (along the old haul road corrido) Adjacent reclaimed slope areas had been properly scalped of cover <br /> soil to allow sufficient room for placement and grading of the new waste material. Appropriate measures had <br /> been taken to maintain proper surface drainage during active dumping and grading operations. The waste will <br /> need to be properly graded and compacted in a timely manner,with design drainage restored, and <br /> compaction test documentation will need to be provided. Future disposal of coaly material from the Unit <br /> Train Loadout is anticipated within this designated portion of CRDA-1. <br /> 5 <br />