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Page four innocent". This attitude seems to be the result of the OSM attack on the Division for failure to enforce the State Coal Program. 4. BASIN'S COMPLIANCE ACTIVITIES Over the past three years, Basin has provided an appropriate level of facilities maintenance to respond to the regulatory requirements. These levels were in direct response to discussions with Division Inspectors and Basin's interpretation of how the regulations were being enforced by the Division. The time and.expense for these activities over the past three years includes both internal and external labor forces. As tasks. were identified to be completed, internal staff were utilized to complete the activities. In an overload condition, contract labor was utilized to complete the necessary activities. Staffing levels of Basin for the last three years in relation to coal production is provided on the attached table. Contract labor for the last three years totalled $95,000 for 1991, $39,0.00 for 1992, and $237,000 for 1993 to date. An additional $235,000 is currently under contract for regulatory compliance to be completed over the next several months. Basin has fulfilled the promises extended to the Division in May 1993 for increased regulatory compliance. This has been accomplished by an increase in the environmental engineering staff and design and maintenance of facilities. Mr. Ralph Lopez was hired in August 1993 and additional contractor support has also been utilized as referenced in the above expenditures. , 5. PLAN FOB REGULATORY COMPLIANCE Basin is in the process of developing a formalized plan to ensure regulatory compliance. The components of this plan are described in the paragraphs below. Requlatorv Compliance Training - Basin is in the process of providing a training program for the operations personnel managing various aspects of the mining and surface facilities operations. The purpose of this training is to establish regulatory compliance awareness for their respective operations. This training will provide the basis to assist in regulatory compliance and to know what activities require revisions to the permit which will. need to be coordinated by the Environmental Engineer. Inspection Manual - By December 15, 1993, Basin will have developed an inspection manual which will provide a listing of the compliance items for field inspection (culvert sizes, ditch 'sizes, sign and marker requirements, etc). This manual will be used by the engineering staff to insure that all items are in compliance at the time of inspection. The manual will contain forms and checklists to be used to document compliance.