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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 /> This was a complete inspection of the Roadside Portals Mine conducted on May 20, 2009 by Mike <br /> Boulay of the Division of Reclamation, Mining and Safety Grand Junction Field Office. Tonya <br /> Hammond of Snowcap Coal Company(SCC) was present during the entire inspection. Weather <br /> conditions were sunny and warm. Ground conditions were dry. <br /> Availability of Records <br /> The availability of records was checked on the afternoon of 5/20. All required records were on file and <br /> available for review at J.E. Stover& Associates offices. No problems were noted with the records <br /> review. Tonya Hammond does an excellent job at maintaining and updating the records file. The <br /> records are organized and easily accessible. See the attached Availability of Records checklist. <br /> Roads <br /> Roads were dry and in good condition. Road ditches and road culverts were generally well maintained <br /> throughout the various mine site locations and support facility areas. <br /> Hydrologic Balance <br /> All site Sedimentation Ponds including 6, 7, 8, 9, 10, 11, 13 and UTL I and 2 were inspected. All <br /> ponds were dry, with exception of UTL 2 and Pond 8. Pond 8 receives a small amount of discharge <br /> from the North Collection Ditch at the South Portals area which originates from the South Portals <br /> French Drain. UTL 2 usually has a greater amount of water during this time of year which is the result <br /> of alluvial groundwater inflow from the Colorado River. Pond embankments, inlets and discharge <br /> structures were all stable and no problems were noted at any of the sediment pond locations. Drainage <br /> and diversion ditches were stable and dry with no significant erosion or other problems noted. <br /> One objective of this complete inspection was to look at various silt fence locations throughout the <br /> permit area that had been included in Technical Revision No. 58 (TR-58) for the purpose of removing <br /> them. With TR-58 SCC demonstrated that vegetation had become established to the extent that the silt <br /> fences were no longer required to treat the run-off from small isolated disturbed areas. SCC utilized <br /> SEDCADTM 4 to evaluate the effectiveness of the vegetation to act as a grass filter. Grass filter <br /> designs are presented in TR-58 for each silt fence that SCC intends to remove. Upon approval of TR- <br /> 58 these designs will be incorporated in to the PAP in Appendix 14-6. All of the silt fence locations <br /> were stable with no significant erosion occurring. In most cases the vegetation was well established. <br /> At a few of the locations, vegetation was sparse but these sites were relatively flat and there was no <br /> evidence of excessive sediment deposition at the silt fence and virtually no erosion occurring. Based <br /> on the site inspection and the design information presented in TR-58, SCC has successfully <br />