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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 />• Segments of the BLM Coal Canyon Road and an adjacent Public Service Company (PSCO) <br />transmission line. <br />No workings of the Roadside North and South Portals Mine were located beneath or adjacent to the Xcel power <br />plant facilities or adjacent segment of 19/10 Road; as such these facilities would not be subject to potential <br />subsidence damage. For this reason, the Xcel facilities were not visited during the bond release inspection. Xcel <br />Energy was notified of the bond release application and inspection, but did not provide comments on the <br />application or attend the inspection. Mesa County Department of Planning and Economic Development <br />(Planning Department) and the Mesa County Commissioners were also contacted regarding the application and <br />inspection, and did not submit written comments or attend the inspection. However, the Planning Department <br />did request a copy of the inspection report by phone, subsequent to the inspection. <br />Based on mine plan maps and Bond Release Map SL-03, a segment of the Government Highline Canal in the <br />SE Ya Section 27, could potentially be subject to subsidence effects. Mine workings from the Roadside North <br />Portal extend beneath slopes immediately to the west of the canal, along a several hundred foot segment of the <br />canal. Lands overlying the workings in this location were included in the liability release area, and the potential <br />for subsidence damage along this segment of canal was of concern to Bureau of Reclamation (BOR) <br />representatives present at the bond release inspection. The canal banks and adjacent slopes in the location of <br />concern were walked and closely checked for surface cracking or other signs of subsidence by the entire group, <br />including BOR representatives, SCC representatives, and myself. No evidence of subsidence damage or <br />surface expression was observed, though rill and gully features and sediment deposition associated with recent <br />storm runoff from the steep slopes west of the canal were noted in several locations. A segment of the canal <br />road along the west bank had been regraded recently to repair storm runoff damage. There is another segment <br />of the canal that passes through the bond release request area further to the south, in the Xcel Power Plant <br />vicinity, but no mine workings are located within this portion of the release area. <br />A BLM road extends up Coal Canyon to the northwest of the CRDA waste disposal areas, within the bond <br />release area, and a Public Service Company (PSCO) transmission line is located adjacent to the roadway. A <br />400 to 500 foot segment of the road, and adjacent area where the transmission line is located, were undermined <br />in the early 1980s, in the NW Ya of Section 28, approximately 500 feet northwest of the Upper Greasewood <br />Reference Area. The permit does not specify protective measures implemented in this area, but no problems <br />have ever been noted by the operator or the Division with respect to possible subsidence damage to the road or <br />transmission line segment, nor have any such concerns been brought to the Division's attention by PSCO, BLM, <br />or the public. The location was checked during the bond release inspection and no subsidence effects (e.g. <br />cracks or settling along the road, or tilting of power poles) were observed. <br />Hydrologic Features-North Portals Area <br />Several intermittent springs had been identified in relatively remote portions of the North Portal mining parcel, <br />and are included within the bond release request area. The springs were not undermined by the Roadside <br />Portals operation, although some of the springs were located in areas where mining had at one time been <br />planned. The springs were monitored for a number of years during April and May (typical period of flow). <br />Termination of the monitoring was recently approved by the Division, due the fact that monitoring had been <br />conducted for a sufficient length of time to establish a record of baseline flows, and also due to the fact that <br />mining activity that could possibly impact the springs is no longer proposed. Due to lack of potential for <br />subsidence impacts to the springs, they were not inspected during the bond release inspection. <br />Portions of Coal Creek (an ephemeral stream) and Jerry Creek (an intermittent stream) are located within the <br />bond release area. Both creeks were undermined by North Portal workings along certain segments. A short <br />segment of Coal Creek in the NW'/a of Section 28 was undermined (same general location as described <br />5 <br />