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III. COMMENTS -COMPLIANCE <br />Below are comments on the Inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />The purpose of this inspection was to verify the total cover depth and the topsoil cover <br />depth on the West Ridge waste pile for the partial Phase One bond release (SL-02). A <br />determination of whether a portion of the West Ridge waste pile was on land owned by <br />Kenneth Pavlisick was not possible since the operator had not surveyed in the property <br />line in time for this inspection. The operator will be surveying the property line shortly. <br />This was the second bond release inspection at the Bowie No. 1 Mine for SL-02. The fast <br />bond release inspection was conducted on June 10, 2003. Representing the Colorado <br />DMG was Joe Dudash. Basil Beaz represented the operator. <br />West Ridge Waste Pile <br />The operator used a tracked hydraulic excavator to dig nine test pits on the West Ridge <br />waste pile. Each pit was dug until the top of the refuse was uncovered. Total cover depth <br />and topsoil cover depth were measured in each pit. The locations of the nine test pits aze <br />shown in Figure 1. The locations were chosen in order to obtain a representative <br />sampling of the waste pile cover depth while minimizing the surface disturbance due to <br />the tracked excavator. The cover depth infomlation for each test pit is shown in Table 1. <br />Regulation 4.10.4(5) requires that coal refuse is covered with four feet of non-toxic and <br />non-combustible material. Measurements at eight of the nine test pits showed that this <br />total cover depth was achieved. At the test pit labeled number 2, however, the total cover <br />was 3 feet 8 inches deep. However, this deficiency is considered a localized anomaly <br />since alt of the other test pits showed at least 4 feet of cover. In addition, the deficiency in <br />total cover did not result in any problems with vegetative cover since the vegetative cover <br />over the test pit number 2 was similaz to the vegetative cover over other azeas of the <br />waste pile. <br />The pemut application requires that 8 to 9 inches of topsoil be placed on the West Ridge <br />waste pile. The topsoil depths measured in the nine test pits were at or in excess of the <br />minimum of $ inches that aze required. <br />Reclamation Task Sheets <br />Attached are updated summary sheets 1 of 4 and 3 of 4 that replace the original sheets <br />presented in the June 10, 2003 bond release inspection report. DMG tasks numbers 25 <br />and 100 were updated as a result of this inspection. <br />c:/word/bowie 1 /insp0703 <br />