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III. COMMENTS -COMPLIANCE Below aze comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. In a letter dated August 6, 2007, the Division requested an itemized list of the structures, and the amount of reclamation bond for each structure, for which BRL is requesting bond release. Such a list was provided to the Division in an a-mail dated August 6, 2007. The submittal was called complete on August 9, 2007. The field inspection was scheduled for September 5, 2007. Notification letters for the field inspection were sent on August 14, 2007. Because the Bowie No. 1 Mine is a federal mine, the Office of Surface Mining (OSM) was contacted concerning the bond release field inspection. OSM declined to attend the field inspection. BRL was the only landowner of the land where structural demolition had taken place so they were the only landowner informed of the field inspection. As part of the adequacy review of SL-3, the Division requested that BRL provide a notarized statement that certified that all of the reclamation activities were done in compliance with the rules and the approved reclamation plan. This notarized statement was sent to the Division in a letter dated August 23, 2007 and received at the Division on August 27, 2007. The partial phase one bond release field inspection took place on September 5, 2007 at the unit train loadout. Representing BRL was Basil Bear and Jim Stover, BRL's consultant. Representing the Division were Sandy Brown and Joe Dudash. After the field inspection, BRL submitted a letter dated September 5, 2007 and received at the Division on September 7, 2007 in which BRL requested bond release for some of the spur line track that had been removed from the site. Unit Train Loadout History The unit train loadout, located along State Highway 133 just east of Paonia, was built to receive coal by haul trucks and load and ship coal by railcar from the Orchard Valley Mine. The Orchard Valley Mine and train loadout, owned by Colorado Westmoreland, Inc. (CWI), began operations in 1975 before passage of the Surface Coal Mining and Reclamation Act (SMCRA). [n 1986, the Orchard Valley West Mine portals were built as a temporary substitute for the original mine portals which had experienced a mine fire. The unit train loadout continued to serve the West Mine. [n 1989, the permit was transferred from CWI to Cyprus Orchard Valley Coal Corporation (COVCC). The West Mine operated until 1993 when coal could once again be extracted from the original mine and shipped out through the unit train loadout. The permit was transferred in 1994, this time from COVCC to Bowie Resources Limited, which later became Bowie Resources LLC. The mine was renamed the Bowie No. 1 Mine. Mining eventually ceased at the Bowie No. 1 Mine in December 1997. However, the Bowie No. l Mine train loadout continued operations by shipping out coal that had been mined at the Bowie No. 2 Mine. The Bowie No. 2 Mine, which had been constructed in 1997, utilized the Bowie No. 1 Mine unit train loadout until a new unit train loadout was constructed for the Bowie No. 2 Mine in 2002. Small shipments of speciality coal from Bowie No. 2 went through the Bowie No. I Mine unit train loadout for a while but, eventually, the Bowie No. 1 Mine unit train loadout was idled.