INSPEC10723

• Permit No: C1981041
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 5/22/2007
• Media Type: D
• Archive: No

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III. COMMENTS -COMPLIANCE
Below are 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.
General Comments
This was a partial mine site inspection. Purpose of the inspection was to view the portal bench area and discuss
the AOC variance reclamation plan for that area, which has been proposed in Permit Revision No. 3 (PR-3),
currently under review. Snowcap Coal Company (SCC) representatives had specifically requested that DRMS
request input from the Office of Surface Mining (OSM) regarding the area delineated as "highwall", within the
PR-3 application. The steep face exposed in the immediate area of the portals, and delineated as "highwall" in
the PR-3 application, would be backfilled, but portions of the nearby steep rock cut slopes would remain
exposed, to allow for retention of facilities on the mine bench that are needed for the alternative land use
proposed in PR-3. The areas of backfilled highwall, remnant steep rock cuts, and the mine bench fill would not
be reclaimed to approximate original contour (AOC) under the proposed PR-3 reclamation plan, but would be
approved under the steep slope AOC variance provisions of the regulations, to allow for retention of the portal
bench facilities that would be used in the proposed commercial postmining land use.
In addition to myself, Tonya Hammond of SCC and Jim Stover of J.E. Stover & Associates (consultant to SCC),
were present, along with Henry Austin, of the OSM Western Regional Coordinating Center. Henry indicated that
the highwall delineation as described appeared to be consistent with previous delineations in other states, with
which he was familiar, and with which OSM had concurred. It was agreed among the parties present that the
Division would provide a draft decision document to OSM prior to issuance of a proposed decision on PR-3, and
that OSM's written comment regarding compliance of the portal bench grading plan with applicable steep slope
AOC variance and highwall elimination provisions of the rules would be requested, prior to issuance of a
proposed decision on PR-3.
Weather was partly cloudy and cool during the inspection; ground surface was dry in most areas. There has
been no activity on the mine bench area in recent months, and site conditions on the bench and along Access
Road 1 appear not to have changed since the most recent complete inspection, conducted in March 2007.
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