2014-07-24_INSPECTION - C1980007 (2)

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June 24, 2014 C- 1980- 007/West Elk Mine Inspection Topic Summary NOTE: Y= Inspected N =Not Inspected R= Comments Noted V= Violation Issued NA =Not Applicable N - Air Resource Protection N - Roads N - Availability of Records R - Reclamation Success R - Backfill & Grading N - Revegetation N - Excess Spoil and Dev. Waste N - Subsidence N - Explosives N - Slides and Other Damage N - Fish & Wildlife N - Support Facilities On -site R - Hydrologic Balance N - Signs and Markers N - Gen. Compliance With Mine Plan N - Support Facilities Not On -site N - Other N - Special Categories Of Mining N - Processing Waste R - Topsoil COMMENTS This was a partial inspection of the West Elk Mine conducted by Jim Stark of the Colorado Division of JRS Reclamation, Mining and Safety. The focus of this inspection was to conduct the Partial Phase III Bond Release Inspection for application SL -06. Howard Strand, representing the Office of Surface Mining (OSM); Jessica Loveland, representing Mountain Coal Company, LLC (MCC); Dan Gray, representing the US Forest Service (USFS); and Desty Dyer, representing the US Bureau of Land Management (BLM) accompanied me on the inspection. Kathy Welt and Weston Norris, representing MCC were present for the office portion of the inspection. The weather was hot and sunny and the ground was dry. As stated above, the inspection was in response to an application for a Partial Phase III Bond Release application, SL -06, submitted by MCC. The application was submitted on 3 December, deemed incomplete on 13 December 2013 and deemed complete on 7 March 2013. The application requested the release of approximately 24.2 acres of surface that was reclaimed between 1996 and 2002. The areas include the Lone Pine facilities area (waste development pile, power line corridor, borrow area and portal area), the thermal event area (the "main" area and holes B, D, I and G) and methane drainage well pads and roads along the West Point Road (pads 14 -06, 14 -07 and 14 -08 and the road spur from pads 15 -07 to 14 -09). MCC has not requested a specific dollar amount for release. This amount will be determined prior to proposing a decision. The thermal event areas were approved for a Phase I Bond Release with the approval of Sl -0 1 on 14 October 2005. The Lone Pine area was approved for a Phase I Bond Release with the approval of SL -02 on 2 November 2005. The MDW pads and road were approved for a Phase I Bond Release with the approval of 51 -03 on 10 August 2012. All of these areas were subsequently approved for a Phase II Bond Release with the approval of SL -04 on 8 July 2013. The inspection began at the mine office, with all of the above named parties present. There was a short meeting (approximately 30 minutes) held in the conference room. The purpose of this meeting was to discuss the criteria for a Phase III Bond Release and the criteria that would be observed at the West Elk Mine in particular. I then proceeded to discuss the Bond Release process following the inspection. Finally, we discussed a plan for completing the field portion of the inspection. Following the Division's documentation of the observations in the field, a detailed review of the Bond Release application will be completed. This will focus, in particular, on the mine's vegetation monitoring reports from 2012 and 2013, If the field observations and the vegetation monitoring Number of Partial Inspection this Fiscal Year: 11 Number of Complete Inspections this Fiscal Year: 4 Page 2 of 30