2016-12-23_GENERAL DOCUMENTS - C1980007

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West Elk Mine Partial Phase I Bond Release SL-10 Findings Page 6 of 8 equipment, or de-gas housing will be removed from the site. 2. When the mud pit or pits are sufficiently dry, they will be filled with stored soil material and compacted to minimize any settling. 3. A backhoe and a bulldozer will redistribute material on and around the drill pad to achieve as closely as practicable the original contour of the site. The area will then be ripped or scarified. The reclamation plan calls for MVB access roads to be restored as closely as possible to the approximate original contour, with an uneven final surface. Approximate original contour for the drill pads and roads was verified during the inspection by visual observation. All of the material that had been stockpiled on each site during the construction phase, had been used during the reclamation phase to achieve approximate original contour (or used in the pad or road cut and fill). Additionally, wellbore locations on the ground surface were inspected for compliance with Rule 4.07.3, which requires that well bore closures be designed to prevent access to the mine workings and to keep acid or other toxic drainage from entering ground or surface waters. Rule 4.07.3 also requires all holes to be marked. MCC provided well abandonment reports in the SL-10 application for all of the plugged and sealed boreholes in accordance with Rule 4.07.3(3), which show that proper plugging and abandonment took place in 2015. No debris, trash, drilling related equipment or de-gas housings were found in the bond release areas. No mud pits were found. Borehole location markers were found at all of the locations. All backfill material appeared to have been properly regraded on disturbed areas in the bond release area, resulting in the disturbed lands blending well with the natural contour of adjacent, undisturbed lands. Cut slopes had also been regraded to blend with adjacent undisturbed lands. Access roads had uneven surfaces, as specified in the reclamation plan. Regraded areas appeared structurally stable, with the exception of a small slump on the 09LWE4X37 pad; it was determined, based on observations of the local topography and of similar features in the surrounding undisturbed area, that this slump was unrelated to MCC’s disturbance but was likely the result of a naturally occurring groundwater seep. No tension cracks, head scarps, or compression bulges were found. All areas appeared to have positive drainage, with no low spots in the regraded areas that would allow runoff to pond. There were no signs of excessive erosion (e.g., rills, gullies, or sediment fans). The operator made ample use of downed trees and other slash in the bond release area for erosion control (and for preventing motor vehicle access) by placing the downed trees and slash across reclaimed pads and roads. Backfilling and grading on most of the disturbed sites has created gentle slopes having slope lengths less than approximately 300 feet long, indicating that surface flow is likely to drain across the disturbed area chiefly as sheet-flow, rather than more erosive concentrated-flow. No berms or other obstructions were left on the downslope edges of disturbed areas that would impede flow off of the disturbed lands. While not a Phase I standard, all of the topsoil had been replaced on the drill pads and roads and vegetative growth was apparent on all of the reclaimed drill pads and roads. This vegetation will help to further stabilize the reclaimed areas and control erosion.