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III. COMMENTS - COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of ot~servations made <br />during the inspection. Comments also describe any enforcement actions takers during the <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection conducted by Kent Gorham of the Colorado Division of <br />Minerals and Geology. Ron Thompson represented Basin Resources during the inspection. <br />This former underground mine is now reclaimed. Activities consist mainly of monitoring <br />and maintenance. The weather was warm and ground conditions were dry. <br />Revegetation <br />Vegetation is dry and the growing season is effectively over. Numerous frosts have <br />occurred since the last inspection. We traversed on foot the eastern side of the main <br />facility area, the topsoil borrow area, and pond 3. We discussed possibly cutting or <br />mechanically working the pond 3 area since it's approved post-mining land use is <br />pastureland. Weeds, especially in the southern portion of the pond 3 reclaimed area. are <br />abundant. This area should be managed as a pasture during the reclamation liability <br />period, similar to the pastureland or AVF reference area. Mr. Thompson indicated during <br />the August inspection that weeds would be sprayed when temperatures cool. This task <br />remains to be completed. <br />Soil Methane Monitoring <br />The two gas wells on the Toupal property to the east of the reclaimed area were also <br />visited. The eastern-most gas well (28-10) had a pressure gauge installed on the <br />Bradenhead valve located at the surface/casing interface. The gauge i°eading was 20 psi. <br />Mr. Thompson indicated that the pressure was 50 psi when the gas oper+jtor originally <br />installed the gauge but had stayed at 20 psi following venting and re-installation. The <br />western gas well (28-11) did not have a pressure gauge attached. No :significant changes <br />in the vegetation die-out areas were noted. We discussed how the completion depth of <br />each individual soil gas monitoring well may be related to the variations in gas <br />concentrations. It is likely that any soil gas monitor completed in or near the <br />underlying terrace deposit would return consistantly high levels of methane. Those <br />completed where a sufficient thickness of clay soil remains below the total depth of the <br />soil well may return inconsistent or variable methane readings. The gas operator will <br />be proposing an abandonment plan in the near future. The Chavez coal exploration site <br />has not been mitigated yet due to difficultly in securing a drill rig to do the work. <br />Overall, the site is in good condition considering the extended dry weather. <br />Page 3 <br />