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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 />Item 031 should be amended to include backfilling/grading of the twosmall area exemption sediment traps <br />at the North Decline. <br />Item 053 has been satisfactorily completed for Phase I bond release, and can be deleted from the amended <br />cost estimate. <br />Item 055 can be amended as follows, based on the bond release inspection: <br />• All sealing and backfill costs for South Fan can be deleted (work satisfactorily completed). <br />• Roadside Portal concrete seals satisfactorily completed, but portals outby seals not backfilled. <br />• Cameo portal openings have been satisfactorily sealed andbackfilled. <br />• All portal sealing and reclamation grading associated with the 2-West Portals has been <br />satisfactorily completed. <br />• Although N/W intake portal has been sealed and backfilled, it is recommended that the <br />associated reclamation costs be retained in the amended estimate, because of settling crack <br />noted during the inspection along the crest of the backfill, which was only recently repaired, <br />and which could be indicative of potential backfill instability. <br />Item 089 has been satisfactorily completed, and can be deleted from the amended cost estimate. <br />Items 99a through 99d (structural demolition) can be modified as follows: <br />99b. Demolish conveyor from Transfer Point #2 to #3. This cost item should be amended to <br />reflect the fact that the metal conveyor structure and belt have been removed, but the concrete <br />supports (footers) remain. Several exposed footers were measured 8 feet long by 18" wide, <br />by 19" thick. Tonya Hammond said thickness varied from 9" to 19". The footers are spaced <br />approximately 9 feet apart (perpendicular to conveyor corridor) along the ent've length of the <br />segment from Transfer 2 to Transfer 3, at the county road). The conveyor tan through a large <br />culvert beneath the Xcel Cameo Station coal haulage access road in this segment, whichwill <br />remain in place. The dollar amount associated with demolition of this segment of conveyor in <br />the current estimate is $24,180.00, but the cost of footer removal is not separated out from <br />metal structure demolition. It is not clear whetherregrading cost is included in the demolition <br />cos[ or no[; there is not a separate task for conveyor corridorregrading. <br />99b. Demolish Conveyor from Transfer Point #3 to #4. At the beginning of this segment, the <br />conveyor ran through an 8' diameter heavy guage steel culvert. The outlet end of the culvert <br />where it emerges from beneath the road fill, extends for approximately 200 feet, passing over <br />the channel of lower coal creek. There is no reason that this exposed section of the culvert <br />would need to remain in place for thepostmine use. It is not clear that cutting and removal of <br />this culvert section was factored in the conveyor removal task item, nor was it addressed <br />elsewhere in the estimate. A similar, though shorter, culvert segment exists midway along the <br />segment where the conveyor passed under the rail spur and UTL haul road. This culvert <br />would be removed as a component of road reduction and rail spur reclamation. A number of <br />the concrete footers in the vicinity of this culvert have been dislodged, but remain on site in <br />the immediate vicinity. Along the remainder of the segment, the footers remain in place. The <br />