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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during <br />the inspection. Comments also describe any enforcement actions taken during the inspection and the <br />facts or evidence supporting the enforcement action. <br />This was a complete inspection and a paztial Phase I bond release inspection of the Cazbon Junction Mine <br />conducted by Tom Kaldenbach of DRMS. Mike Savage of Savage and Savage Environmental represented <br />the mine operator. The bond release inspection was conducted in response to the operator's filing of a <br />partial Phase I bond release application (SL-03), which the DRMS received August 26, 2006 and found <br />complete on October 12, 2006. SL-03 requests Phase I release for backfilling, grading, and drainage <br />establishment on approximately 30 acres (the "bond release area"). The bond release area includes the <br />following areas: the North Pit, North Pit Haul Road, Topsoil Stockpile #2, azeas within the Previously <br />Reclaimed Spoil Area (PRSA), South Pit Drill Pad, Equipment Storage Yard, and ancillary azeas. The <br />bond release inspection was conducted in accordance with Section 3.03.2(2). The mine operator owns all <br />of the land, the surface mineral rights, and coal mineral rights in the permit area. The Division had <br />previously notified the Office of Surface Mining of the bond release inspection, but they did not attend. <br />Mining activities on the site ceased in 1988. The former South Pit received final bond release in 2004. The <br />approved postmining land uses for the permit azea aze residential, wildlife habitat, and dryland farming. <br />The ground was dry during the inspection. <br />Availability of Records <br />All required records were on file at the office of Goff Engineering in Durango (see attached list). <br />Suns and Markers <br />Permit boundary mazkers were properly displayed at the numerous locations inspected. Topsoil markers <br />were properly displayed on the only remaining stockpiles: 4, 7, and 8. Amine i.d. sign (including the <br />DRMS address and phone number) was properly displayed on the only public road entrance into the permit <br />azea. <br />Roads <br />The asphalt-surfaced segment of the haul road was in good condition. The asphalt-surfaced segment ofthe <br />haul road (the "Main" haul road) and the segment of the haul road leading to North Pit (the "North Pit Haul <br />Road") have previously been approved for permanent retention, as documented in Appendix 5-1 of the <br />permit application. The width of the North Pit haul road has been reduced to 30 feet as specified on page <br />5-26 of the approved reclamation plan. The road surface of the North Pit haul road was in good condition <br />during the inspection, with the exception of the following three locations where gullies aze beginning to <br />form: neaz the top of the road (at the south end of North Pit), at the sharp turn midway up the road, and at <br />the south (lower) end of the road. I discussed with the operator's representative the need for improving <br />drainage control at the three locations. A water baz constructed of rock was discussed as a suitable method <br />for directing runoff across the road at each of the three locations. <br />3 <br />