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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 /> This was a partial coal inspection conducted by Jason Musick of the Colorado Division of <br /> Reclamation, Mining, and Safety (Division) on 13 October 2008 through 16 October 2008, The <br /> purpose of this inspection was to evaluate the on-the-ground condition with respect to Trapper Mine's <br /> Phase I, II, and III bond release applications, SL-08, SL-09 and SL-10 respectfully, in accordance with <br /> Rule 3.03.2(2). Dan Hernandez of CORMS, Christine Balks of OSM, and Graham Roberts of TMI <br /> accompanied all four days of the inspection. Forrest Luke of TMI accompanied the inspection on 13 <br /> October and Jennifer Maiolo of BLM accompanied the inspection on 14 October. The weather was <br /> clear and the ground was dry during the on-the-ground inspection of the site. All areas to be <br /> inspected were accessible and visible. <br /> Lands requested for liability release under SL-08 include 476.6 acres of land reclaimed between 2003 <br /> and 2007, Lands requested for liability release under SL-09 include 294.6 acres of land reclaimed <br /> during 2002 through 2004. Lands requested for liability release under SL-10 include 305.2 acres <br /> reclaimed from 1996 through 1998. Surface land ownership is private (Trapper Mining Inc.) and State <br /> (Colorado State Land Board). Sub-surface ownership is both Federal and State. Representatives <br /> from the Office of Surface Mining and the Bureau of Land Management accompanied the inspection. <br /> Lane Osborn, the northwest Colorado State Land Board Representative, was notified of the inspection <br /> and declined to attend. <br /> Hydrologic Balance <br /> Reclaimed drainages in parcels D-B-04, D-C-04, H-C-03, F-AB-02, F-AB-03, F-AB-05, F-AB-04, and <br /> F-AB-06 of both SL-08 and SL-09 were inspected and found to be in good condition with the exception <br /> of the following repair and maintenance work needing to be addressed: <br /> • Parcel H-C-03, consisting of 20.3 acres and is both Phase I and II under SL-08 and SL-09, <br /> contains a large reclaimed West Pyeatt drainage. Evidence of heavy down cutting and deep <br /> drop downs due to erosion was noted at the boulder check dams. This lower portion of this <br /> drainage will benefit from brush or check dam repair. See photo below: <br /> 1` <br /> • Parcel F-AB-05, consisting of 73 total acres and 56.2 acres in the parcel of note and under SL- <br /> 09, contains a large reclaimed East Pyeatt drainage. Large boulder check dams have been <br /> installed in the drainage. Although the majority of the check dams have held up and <br /> maintained the integrity of the dams, the check dams through the portion of F-AB-05 (56.2ac) <br /> have been compromised. Evidence of heavy down cutting and major movement of the <br />