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section and set it on the ground without dropping material in the river. The pad is currently cleared but <br />Ms. Blomquist indicated that, due to the weight of the crane, it will be an engineered gravel pad when <br />construction is complete. Straw wattles are in place around the disturbed area. However, this is within the <br />100' stream buffer zone and it is unclear whether this activity has been approved by the Division of <br />Reclamation Mining and Safety as required under Rule 4.05.18. MCM does have prior approval for the <br />24" cross-country conveyor and coal storage silo within the stream buffer zone. Because of my role as an <br />oversight authority, I am not as familiar with details of approved activities within each permit as the direct <br />regulatory authority. I will follow up with the DRMS permit lead to discuss recent activities within the <br />buffer zone. Stream buffer zone markers, which are required under Rule 4.02.5, are absent in this area. <br />We discussed stream buffer zone requirements by the coal silo on the rail spur. The demolition <br />contractors have dropped scrap material here, disturbing the land surface along the channel bank. This <br />bank is a finger off of the primary Williams Fork, but is clearly within 100' of the river channel. Again, <br />no stream buffer zone markers were present to alert the contractors they were in an area where surface <br />disturbances require prior approval. This mine permit area was disturbed well before the enactment of the <br />Surface Mining Control and Reclamation Act, and the long-term surface disturbances within the buffer <br />zone such as the silo, rail spur, conveyor system, and stacker are likely on pre -law disturbance areas. <br />However, this does not authorize additional disturbances nor negate the need to mark the edge of the area <br />approved for disturbance. <br />Mr. Nettleton joined us at the end of the inspection while we were at the silo discussing stream buffer <br />zones. I expressed my concern for having disturbances along the channel bank and the need to post buffer <br />zone markers to alert contractors that the area may not be disturbed. Ms. Blomquist and Mr. Nettleton <br />indicated that they had stream buffer zone markers and would install them as soon as possible. <br />No enforcement actions were taken and none were pending as of this inspection. <br />Page 12 <br />