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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments <br />also describe any enforcement actions taken during the inspection and the facts or evidence supponing the enforcement action. <br />Brian Watterson (Watterson) of Twentymile Coal Company (Twentymile) accompanied Byron Walker <br />(Walker) of the Colorado Division of Minerals and Geology (Division) during this inspection. <br />Items of concern from previous inspections include the following: <br />• cleazly indicating boundaries of azeas authorized for disturbance on maps of the Permit Application Package <br />(PAP) (July 12, 2004 inspection). See a discussion under GENERAL MINE PLAN COMPLIANCE below. <br />• an approved design of the sediment control measure for the temporary belt structure storage area (scoria is <br />presently stored here). See a discussion under HYDROLOGIC BALANCE below. (July 12, 2004 inspection) <br />• an approved design of the sediment control measure currently in place for the CYCC office area. See a <br />discussion under HYDROLOGIC BALANCE below. (July 12, 2004 inspection) <br />• an approved design of the sediment control measure for the "Trudy's" corner storage and training area. See a <br />discussion under HYDROLOGIC BALANCE below. (July 12, 2004 inspection) <br />• a number of outdated or conflicting descriptions had been recognized in the PAP with regard to haul roads <br />(28 October 2004 inspection). See discussion under ROADS below. <br />• redesignation of bodies of water and documentation in the PAP is required for the Disposal Area 1 <br />Impoundment and the Wash Plant Thickner Impoundment (including a description of use or operation) (18 <br />November 2004 inspection). See discussion under HYDROLOGIC BALANCE below. <br />• protection of the topsoil storage pile at the North West Mains Ventilation Shafr. See a discussion under <br />TOPSOIL below. <br />• a revision is required to the ls' Half 2004 Subsidence Report (16 September 2004 inspection). See a <br />discussion under SUBSIDENCE below. <br />• the identification sign at the entrance off Routt County Road 27 into the satellite warehouse/storage area <br />(vicinity of the Routt county Roads 27 and 33 intersection) needs to be restored (PAP page 2.05-19)(18 <br />November 2004 inspection). See a discussion under SIGNS AND MARKERS below. <br />The first six items listed above developed over time and from a series of changes in operations with <br />incomplete or conflicting information in the PAP documentation, or without recognition of current <br />interpretation and application of the Rules cited. They need to be accomplished to accurately describe current <br />operations in the PAP. A deadline of January 17, 2005, discussed with Jerry Nettleton of Twentymile on <br />December 9, 2004, is considered appropriate for submission of necessary changes (technical revisions) to the <br />Permit Application Package for the first six items listed. A deadline of January 17, 2005 is also considered <br />sufficient for accomplishment of the other three items. <br />SIGNS AND MARKERS <br />A description of markers delineating the perimeters of areas affected by surface operations or facilities (Rule <br />4.02.3) is found on page 2.05-12 of the PAP (posts with bright fluorescent paint, orange surveyor markers, or <br />fences). Uniformity of markers was questioned during the July 12, 2004 and subsequent inspections. <br />However, in review, this combination of types of markers is considered in compliance with the Rules. <br />The identification sign at the entrance off Routt County Road 27 into the satellite warehouse/storage area <br />(vicinity of the Routt county Roads 27 and 33 intersection) is missing and needs to be restored (PAP page <br />C-1982-056. CP Inspection of December 3, 2004 Page 3 of 7 pages. BGW <br />