_INSPECTION - C1994082 (70) - Laserfiche WebLink

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III. COMMENTS - COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. General Comments This was a quarterly complete inspection of the Yoast Mine. Field inspection was conducted on 4/22/08 and office records were checked on the morning of 4/23/08. The primary field inspection was conducted from 08:50 to noon, accompanied by Roy Karo, Seneca Coal Company(SCC) Mine Manager. Due to turbid discharge from Pond 012 noted during the primary field inspection, I returned to the site later in the day and obtained a water sample at 16:45. Roy Karo chose not to accompany me when I returned to the site to obtain the sample. The field inspection was limited to reclaimed areas accessible from Sage Creek road, specifically Sediment Ponds 012, 013, and 014, and associated reclaimed watersheds, as well as Sediment Pond 011, in the Grassy Creek watershed, which is accessible by maintained roads. All other mine areas were inaccessible due to deep snow on access roads that were not maintained through the winter. Weather was clear and warm. Significant snow cover remains throughout the site, with the exception of south facing slopes, which are largely snow free. Major snow melt from the mine site and adjacent areas of similar elevation had initiated within the past week, with the onset of warmer weather. There was flow in the major ephemeral channels in the sediment pond watersheds, and it was noted that streams in the adjacent and general area, including Sage Creek and Dry Creek, were flowing high and turbid. It was evident that Dry Creek had recently flowed out of its banks along its lower reaches near Hayden. One enforcement action (NOV CV-2008-001)was issued based on observations made and the water sample taken during the inspection. See description and photo documentation below. Description of Enforcement Actions NOV CV-2008-001 NATURE OF VIOLATION AND PORTION OF OPERATION AFFECTED NOV CV-2008-001 was issued May 2, 2008, based on observations made during the inspection on April 22, supported by Pond 012 discharge water sample analysis that indicated apparent exceedance of the 0.5 ml/I settleable solids discharge standard. The NOV was issued for failure to implement proper stabilization, drainage control, grading, and maintenance practices to ensure slope stability, prevent topsoil loss, and minimize disturbance of the prevailing hydrologic balance. This NOV was written due to the reoccurrence of a landslide on a steep slope affected by mining operations in the lower portion of the Sediment Pond 12 watershed, as well as for surface water management practices (scraper road water bar locations)that may have contributed to gully erosion and to slope instability. The soil spreading/grading technique (dozer push downhill) and lack of subsequent seedbed preparation roughening (required by approved permit for broadcast seeded steep slope areas) appears to have resulted in accelerated rill erosion.The toe of the slide has encroached into Pond 12, reducing storage capacity of the pond by some extent. The slope failure and erosion on the slope have contributed to high levels of settleable solids being discharged from Pond 12 (0.9 ml/l, on 4/22/08). The slope where the failure occurred is immediately northeast of Pond 12, has a south facing aspect and a grade of approximately 43% in the vicinity of the failure. There have been at least two previous slope failures in the same location, initially in 2000, and at least one time after repairs of the initial failure were completed. The most recent prior failure in the location was regraded, topsoiled, and broadcast(aerial) seeded in 2007. DRMS was notified of the current slope failure by the operator on 4/18/08. The elliptical shaped slope failure extends approximately 600 feet from west to east across the regraded slope, 3