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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 />stored in the coal waste pile at the Sanborn Creek Mine. After construction of the Bear No. 3 Mine facilities was <br />completed, mining in the C -seam progressed until reserves in that coal seam were exhausted. <br />After the reserves in the C -seam were mined out, BCC then ramped down from the C seam workings to the B- <br />seam coal. This ramp entered the B -seam at a point approximately 300 feet south of the southernmost extent of <br />the Edwards /Clark Mine B seam workings. This meant that a barrier of 300 feet of coal was left in place between <br />the Bear No. 3 Mine B seam workings and the Edwards /Clark Mine B seam workings. Mining then progressed in <br />the B seam, with panels essentially directly below the Bear No. 3 Mine C seam panels. With most of the B seam <br />coal reserves already mined out, BCC decided to close the Bear No. 3 Mine when a large cave -in made further <br />mining uneconomical. Permanent seals were installed at various points in the Bear No. 3 Mine B seam mine <br />workings. <br />On November 11, 1996, BCC permanently ceased all mining operations at the Bear No. 3 Mine due to geologic <br />conditions encountered throughout the mine. The status of the Bear No. 3 Mine became "inactive." All three C <br />seam portals at the Bear No. 3 Mine were sealed on January 9, 1997. Drainage pipes were installed through each <br />of the portal seals so that mine water would not build up behind the portal seals. During 1997, the two <br />warehouses and shop building, mine fan, portal bench transfers, conveyor structure, stacking tube, substation and <br />miscellaneous mine equipment and debris were removed. The Bear No. 3 portals were backfilled according to <br />Mine Safety and Health Administration requirements, and the mine benches and bench access roads were <br />backfilled and graded during June and July of 1997. The facilities bench was graded and topsoiled in 1998. The <br />disiturbed area was, then, reseeded, also in 1998. A sedimentation pond with one collection ditch and one culvert <br />remain on site for sediment control. In order to treat and discharge the hillside spring water, a collection ditch and <br />culvert, the spring water treatment pond and its discharge pipe to the river remain on site. <br />The mine office building was demolished and the combustible debris burned in place in 2007 while the <br />noncombustible material was disposed of offsite during 2008 and 2009. The demolished mine office foundation <br />concrete was broken up and disposed of offsite and the former mine office area was backfilled and graded during <br />2009. The paved access road, bridge and fence remain as approved in the permit. However, Arch Coal Company <br />requested, during the bond release inspection, that the fence be removed. The approved post mining land use is <br />limited residential and undeveloped land. <br />There are three issues occurring at the Bear No. 3 Mine that resulted in the exclusion of the west side of the <br />reclaimed hillside from the SL -4 bond release. First, signs of slope instability, such as cracks and holes, are <br />occurring in the area where two mine portal entries were sealed and backfilled. There is a large landslide <br />immediately adjacent to the western boundary of the Bear No. 3 Mine that was first noticed in 1997. The <br />landslide may be affecting the stability of the reclamation work at these two reclaimed mine portal entries. <br />Therefore, the reclaimed portal area and the reclaimed road portion west of the riprapped hillside drainage <br />channel were excluded from SL -4. <br />Second, there is evidence of a possible thermal event occurring within the mine. Smoke /vapor and the odor of <br />sm6ldering coal have been present in the immediate area of the backfilled mine portal area. The thermal event <br />may be affecting the slope stability and seals of the two backfilled mine portal entries and also may be a public <br />safety concern. Therefore, the area was excluded from SL -4. <br />Third, on the hillside just down gradient of this unstable reclaimed portal area, a spring developed in the area of <br />the old Edwards /Clark B Seam Mine portal just after the adjacent landslide started. The spring water is flowing at <br />about 10 to 15 gallons per minute and is about 100 °F as it comes out of the ground. In June of 1999, the mine <br />4 <br />