2014-08-01_INSPECTION - C1980007

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July 9, 2014 C- 1980- 007/West Elk Mine JRS field, a detailed review of the Bond Release application will be completed. This will focus, in particular, on the well abandonment reports. If the field observations and the well abandonment reports meet the applicable Phase I Bond Release criteria, the Division will draft a Findings of Compliance and Proposed Decision document for SL- 07 and propose a decision to "approve" the bond release. If there are any deficiencies the Division can partially approve SL -07 (areas can be carved out, if necessary). Based on the observations in the field, however, the entire area appears to be eligible for a Phase I Bond Release. BACKFILL and GRADING — Rule 4.14 Contemporaneous Reclamation 4.14.1; Approximate Original Contour 4.14.2; Highwall Elimination 4.14.1(2)(f); Steep Slopes 4.14.2, 4.27; Handling of Acid and Toxic Materials 4.143; Stabilization of Rills and Gullies 4.14.6: - The Division inspected all of the drill pads and light -use roads included in the SL -07 application for Phase I Bond Release criteria. These include hillslope and drainage channel gradients and general design compliance, performance of the reconstructed topography, including symptoms of failure or instabilities such as settling, slumping or cracking; hillslope design /function with regard to erosion; swales and depressions with regard to numbers of features and effect on post- mining land -use (generally not applicable on these small and linear areas); and blending of regraded land to undisturbed areas. -The inspection started on the West Flat Iron Road. The majority of this road was narrowed to an ATV trail at the request of the USFS. As such, both edges of the road were pulled in and the ATV trail runs down the center of the old road. There are a few spots where the road configuration is different. In these locations, where the configuration differs from an ATV trail in the center of the reclaimed road, it will be noted. While the West Flat Iron Road is one continuous road, there were several shorter road spurs off of the main road. These spurs will be discussed independently and include the spur to MDW pad 22- 05/22 -06, MDW pad 19- 04/19 -05 and MDW pad 4- 18 34. The first part of the West Flat Iron Road (approximately the first quarter of a mile) is very steep. Despite the steepness the road was stable and well vegetated at the time of the inspection. The remaining West Flat Iron Road is not as steep. It, too, was stable and well vegetated at the time of the inspection. The reclaimed outer edges of this road segment blended well with the undisturbed. There were no signs of any instability, including any settling, slumping or cracking. There was a portion of the road, from MDW 19- 01/19 - 02/19 -03 to the end of the road, where the left side of the road (basically the west side) only was reclaimed. Again, the remaining portion of the road was left as an ATV trail. This reclaimed portion of the road was stable and there were no problems noted. The remaining portion of the road that was left as an ATV trail was also stable, with no signs of any slumping, settling or cracking at the time of the inspection. There were no erosional problems noted on any portion of the West Flat Iron Road, this includes the reclaimed portion and the portion left as an ATV trail. - Although a part of the main West Flat Iron Road, the segment from MDW pads 19 -01, etc and 1- 18 -41, etc. was fully reclaimed. The road segment was well vegetated and stable at the time of the inspection. The regraded road blends in well with the surrounding undisturbed areas and appears to meet AOC. The road has positive drainage and there was slash placed on the road to help control runoff and limit access. There was no evidence of any instability on the site, including evidence of slumping, settling or cracking. There were no erosional problems noted on this road segment at the time of the inspection. - As stated above, there is a short spur off of the main West Flat Iron Road that runs to MDW pad 22- 05/22 -06. This road spur was also reclaimed to an ATV trail. As with the majority of the West Flat Iron Road, the outer edges of the existing road were pulled in and reclaimed, leaving the ATV trail in the center of the road. Both the Number of Partial Inspection this Fiscal Year: 1 Number of Complete Inspections this Fiscal Year: 0 Page 3 of 54