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III. COMMENTS - COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of <br />observations made during the inspection. Comments also describe any enforcement <br />actions taken during the inspection and the facts or evidence supporting the <br />enforcement action. <br />This was a partial inspection conducted by Tom Kaldenbach of the Colorado <br />Division of Minerals and Geology. Sandra White represented the operator. <br />With the operator's consent, this report was issued from the Denver office. <br />The ground was covered with less than one foot of snow, which limited <br />inspection. <br />The longwall was active in panel 14 Right. <br />Availability of Records <br />The need to submit copies of the following items to the Division was <br />discussed during the inspection: <br />1. As-built certifications for the northwest vent shaft access <br />road and the batch-weigh haul road; <br />2. First-half 2002 subsidence report; <br />3. Pond inspection reports for 2nd and 3rd quarters 2002; <br />4. Updated ownership and control information for permit renewal <br />RN-04. <br />The operator has copies of all of these items available in the mine <br />office. During the inspection, the operator's representative provided <br />the inspector with a copy of the subsidence report (which was about to <br />be mailed), and explained that the ownership and control information <br />was sent to the Division a few weeks earlier (the inspector will check <br />to see if the submittal was received). The as-built certifications <br />and pond inspection reports will be mailed to the Division. <br />Hydrologic Balance <br />Brian Watterson of Twentymile Coal Company described a suspected <br />exceedance of the instream sulfate limitation that occurred at monitoring <br />site 1005 on Trout Creek. Preliminary information is shown on the <br />accompanying map. The exceedance occurred earlier in the week of the <br />inspection, a few days after pumping had stopped at the Fish Creek <br />borehole. Pumping at the Fish Creek borehole could have contributed to <br />(or increased) such an exceedance, although the situation is complicated <br />by a lag between the time pumping ceased and the time the exceedance was <br />detected. Also, there is a probable significant inflow of sulfate into <br />Trout Creek upstream at the Edna Mine. The material damage suspect level <br />of 1000 micromhos/cm was not exceeded at site 1005. Once Twentymile's <br />analytical results are received from the lab, parameter values at the <br />monitoring sites can be evaluated for compliance. Mine pumping from the <br />3 <br />