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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 />• dollar amount associated with demolition of this segment of conveyor in the current estimate <br />is $51,140.70, but the cost of footer removal is not separated out from metal structure <br />demolition. There are no separate task items for conveyor corridorregrading or culvert <br />removal. In addition to the items discussed above, conveyor has been pulled from the river <br />span tube, but the river span and associated supports, along with all of the conveyor transfer <br />buildings remain in place. <br />• 99b. North Decline Area. The two tasks listed (demolish treatment building and remove <br />miscellaneous equipment and materials) have been satisfactorily completed, and the tasks can <br />be deleted. <br />Item 111 (Regrade All South Lease Exploration Roads). Based on inspection and consultation with BLM <br />(the surface owner), DMG has determined that sealing ofdrill holes, and regrading of drill sites and <br />associated roads has been satisfactorily completed. As such, this item can be eliminated from the amended <br />cost estimate. <br />In summary, the Division has concluded that in a number of instances, reclamation meeting phase I bond <br />release requvements has been completed, and reclamation liability can be reduced accordingly. The <br />operator had requested bond release "credit" for replacement ofnon-toxic cover and topsoil on the lower <br />benches of refuse azeas CRDA-1 and CRDA-2. However, for reasons discussed in other sections of this <br />report, the Division does not consider bond release to be appropriate for refuse piles with substantial <br />reclamation work yet to be performed, and the Division's amended cost estimate will not reFlect credit for <br />cover placement. It is Division policy as outlined in the Guideline Regarding Selected Coal Mine Bond <br />Release Issues, that bond release for topsoil replacement is evaluated as a component of Phase 2, but not <br />Phase I bond release applications. <br />Phase 1 Bond Release Evaluation <br />The following additional items are considered during Phase 1 bond release/evaluation, pursuant to Rule <br />3.03.1(1), 3.03.1(2)(a), 3.03.1(3)(d), and the Guideline Regarding Selected Coal Mine Bond Release Issues. <br />(1) Structural demolition removal in accordance with approved reclamation plan--- <br />Structural demolition/removal was observed to have been fully completed in accordance with permit <br />requvements at the North Decline, and largely completed at the 2-West Portals and South Fan. A[ [he 2- <br />West Portals, demolition of the electrical substation and powerline remained to be done, and these facilities <br />were not included in the bond release application. All structures have been removed from the South Fan <br />site, but fan components, transformers, and other miscellaneous items removed from the facility site were <br />temporarily placed at thejunction of the reclaimed South Fan Road and the 2-West Portals road. Along the <br />conveyor corridor, [he conveyor itself has been removed, but concrete footers remained in place. Other <br />structures along the conveyor route [hat remain in place include the river span and associated structures, the <br />transfer buildings, and a 200 foot section of 8' diameter culvert that extends to the north of the county road <br />near Transfer 3. <br />