_ENFORCEMENT - C1981017 ‎(12)‎

• Permit No: C1981017
• IBM Index Class Name: Enforcement
• Doc Name: Bid Documents ‎(IMP)‎ Violation CV-91-02-355-002
• Media Type: D
• Archive: No

Time available for inspection was getting short as we headed up to
portal # 5. Problems existed with the road, but not with the
severity that they existed with the other haul/access roads,
probably due to the gentler grade. Non-coal waste was present on
this portal pad. In addition the shop had been ruined by an
avalanche, and debris and ruined furnishings were strewn throughout
the interior of the building. Mitch wrote a violation in his TDN
addressing the ditch carrying disturbed area run-off from the pad
to the pond. This channel had been repaired and riprapped. A
contractor was on site doing AML work just below the disturbed
area.
Immediately prior to terminating the inspection we inspected the
area around the warehouse, assessing which piles of material had
potential to be useful and which were non-coal waste. This area
needs to be policed and non-coal waste and oil and grease sources
need to be removed.
Conclusion As noted above as necessary, abatement work is
proceding on violations written last October, though on some
situations it is at quite a slow pace. Additionally, and
unfortunately, some of the remedial work done to abate the
violations is already in need of maintenance and/or is degrading
at such a rate that non-compliance is imminent without some work
being done again. When the abatement procedures call for riprap
the company must find some way to size the material, even hand
picking, to ensure that fines will not be placed in any drain.
I was aware from various reports that the mine was in a state of
disrepair. However, it became apparent when on site that serious
violations existed. The road drainage system was not configured
according to design, apparently from lack of maintenance. Ditches
and downdrains alternate from being silted in to being severely
eroded. The eroded areas, the downcutting in the drains, the
opaque run-off during the storm event and the fine-laden material
used for rip-rap leaves no doubt that the roads have been
contributing additional suspended solids to the stream during
rainfall events. Because of the need for immediate action I issued
a two part TDN on site, making my concerns fully known to the
operator and state. I also stated that if the State did not write
it I would have no recourse but to come back on site and with the
aproved design in hand, walk every linear foot of the roads and
determine if the roads and the drainage structures were built
according to design. I would do this with the intent of acting to
protect the hydrologic balance as best I could with the tools I had
to work with, ie the performance standards and the approved
designs. It would not be a decision that the approved designs were
the best technology to address either the State's or the Forest
Service's concerns on the roads. I in no way wanted to minimize
or negate the sincere efforts of everyone involved in the road
review, but of course had to address the violations that were
apparent. The TDN was written for 1) failure to minimize
disturbance to the hydrologic balance from the mine roads by