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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments <br />also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. <br />Jerry Nettleton (Nettleton) or Sandra White (White) of Twentymile Coal Company (Twentymile) <br />accompanied Byron Walker (Walker) of the Colorado Division of Minerals and Geology (Division) during <br />this inspection. <br />A number of references to other permits, once concurrent with C-1982-056, continue to appeaz in parts of the <br />Permit Application Package (PAP) for on-site features. The PAP needs to be modified to incorporate (collate <br />and correlate information) to include such features so that the current PAP is a stand-alone document. A <br />complete and comprehensive review of the PAP by the Division is scheduled (mid-term review) to begin on <br />May 2005. <br />AVAILABILITY OF RECORDS <br />See attached worksheet. <br />SIGNS AND MARKERS <br />Identification signs at entrances off public roads were in good repair. Topsoil storage pile identification signs <br />were in place. Disturbance azea boundary markers were found in place at the 18-Right Ventilation Shaft and <br />road sites, and about the explosive and material storage site. <br />ROADS <br />A weazing surface had been placed on the access road to the 18-Right Ventilation Shaft site. <br />A number of haul road descriptions in the PAP need to be clarified (see Division Inspection of 28 October and <br />November 18, 2004). A relocated mine waste disposal Area 1 road is now used as a haul road (see Map 24A, <br />11/12/96, of the PAP) for coal mine waste from the coal preparation plant to coal waste disposal Area 2. In <br />addition, the spur from this segment to the waste rock storage bin, approved as a part of the processing plant <br />modification (TR-18, 1995), needs to be shown (culverts are shown) on the appropriate maps and included as <br />a spur haul road. A reference to a redefinition of Haul Road B (Map 30A) was found in the PAP, but a copy of <br />this map was not found during this inspection or in the Division files upon return to Denver. During the <br />December 3, 2004 inspection, the relocated mine waste disposal Area 1 road could not be used to haul coal <br />from the tipple area to the truck scales. Coal trucks could not negotiate the changing road locations through <br />the coal storage areas. During this inspection, coal highway trucks were using the Area 1 road and negotiating <br />through the coal loadout area (a train blocked the Haul Road C -Haul Road B route). <br />HYDROLOGIC BALANCE <br />There was about a foot of snow over the site. Ponds were frozen over, with the exception of the Waste <br />Disposal Area 1 pit. <br />There were discharges from B, C, D, and the Fish Creek Tipple ponds. <br />C-1982-056. CC Inspection of January 4, 2005, Page 3 of 6 pages. BGW <br />