_INSPECTION - C1980005 ‎(9)‎

• Permit No: C1980005
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 7/14/2009
• Email Name: DTM
• Media Type: D
• Archive: No

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.
The corridor is approximately 2100 feet in length, and encompasses approximately 1.5 acres.
The eastern(and topographically lower) segment of the corridor is Postmine Channel PM-12A,
which was constructed along a former scraper route where gully erosion had developed. The
western segment of the corridor(approximately 900 feet) is the equipment access route used for
PM-12A construction, along the slope contour on a reclaimed haul road segment. The 1.5 acre
corridor was not included in SL-1; PM-12A construction was completed subsequent to SL-1
submittal and approval. Observations and measurements made during the site inspection on
7/14/09 indicated that the PM-12A TRM lined channel appeared to be stable and functional, with
gradient and capacity in conformance to design specifications. Vegetation establishment along
the channel was variable; sparse and dominated by annuals and sweetclover in some segments
(Photo#472&473), good to excellent perennial establishment in other segments,particularly the
lower half of the channel (Photo #474). Minor rill erosion and relatively poor establishment of
seeded vegetation was noted along short, steep channel access routes at the extreme upper and
lower ends of the channel. Scarification and seeding of these locations may be warranted, but
will be addressed as a maintenance issue which will not affect determination regarding SL-4.
Photo #471 shows the steep access route segment along the upper end of the PM-12A channel.
No problems were observed along the lower gradient segment of the access corridor between
Road E-1 and the PM-12A channel; the travel route appeared to have been properly scarified and
seeded, with adequate initial vegetation establishment.
One issue of concern was identified by the Division subsequent to the SL-4 inspection, which
will need to be resolved in order for the 1.5 acre corridor to be approved for Phase 1 bond release
within SL-4. The lower-most segment(approximately 300') of PM-12A curves to the north and
runs into Channel PM-13, which reports to Sediment Pond/Permanent Impoundment 008. This
alignment is consistent with the channel location as depicted on SL-4 Map Exhibit A,but is not
in accordance with approved permit Map Exhibit 13-2A and other permit exhibits depicting the
approved postmining topography and drainage network. Permit approved designs show that PM-
12A curves to the south at its lower end, such that it ties into PM-12, which reports to
Sedimentation Pond/Permanent Impoundment 004. This inconsistency was brought to SCC's
attention by the Division(see inspection report dated 8/21/09), and in response SCC submitted
an application for technical revision(TR-51). TR-51 was deemed administratively complete on
September 18, 2009 and is currently under review. The revision proposes modifications to the
approved permit to accurately reflect the actual channel alignment, including associated revisions
to runoff and sediment modeling documentation for the Pond 004 and Pond 008 watersheds. In
the revision application, Channel PM-12A has been re-designated PM-13A, reflecting the fact
that it is tributary to Channel PM-13. The 1.5 acre corridor associated with PM-12A as
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