_INSPECTION - C1982057 ‎(33)‎

• Permit No: C1982057
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 10/14/2009
• Email Name: DTM
• Media Type: D
• Archive: No

III. COMMENTS-COMPLIANCE
Below are comments on the inspection. The comments include discussion of observations made during the
inspection. Comments also describe any enforcement actions taken during the inspection and the facts or
evidence supporting the enforcement action.
Proposed permanent roads in the original permit block(North Area)that were included within
the SL-2 release request area include Road "G", the Ridgeline Access Road, the Oil Well Access
Road [which is a short upper segment of Routt County Road (RCR) 53C], a Section of Road"J",
and all or portions of permanent light use roads LU-1, LU-3, and LU-4. These roads are denoted
on Exhibit B (Phase I Bond Release Postmine Topography and Drainage) of the SL-2
application. The approved permit contains necessary permanent retention documentation
including landowner letters and As Built drawings for Road"G" and the Ridgeline Access Road.
Landowner request letters have been provided for the various light use road segments listed, the
Oil Well Road segment of RCR 53C, and for the segment of Road"J"within the North Area.
However, As Built drawings documenting conformance with applicable performance standards
and permit specifications for permanent roads had not been provided for these road segments at
the time of the SL-2 inspection. Permit Attachment 20-2 text includes commitments to provide
As Built profile and cross-sections for each of the permanent light use roads, RCR 53C, and
Road "J", prior to Phase I bond release request. The"J"Road As Built cross-sections in the
approved permit reflect the operational road width, and do not reflect reclamation modifications
including the reduced travel width.
One additional observation made during the SL-2 inspection, is that there is a short segment of
light use road within the disturbed area near the substation site (LU-IA). The road extends along
the ridgeline from the curve on LU-1 approximately 500 feet to the northwest,where it ties into
an existing ranch road outside of the disturbance boundary. The road is included within the SL-2
release request area,but has not been proposed as a permanent road within Permit Attachment
20-2, nor is it depicted on SL-2 Exhibit B.
Until required final reclamation As Built documentation is incorporated into the approved
permit for proposed permanent Road "J", the Oil Well Section of RCR 53C, Light Use
Roads LU-1,LU-lA, LU-3, and LU-4, the Division will not approve Phase I bond release
for the road segments. A technical revision application to incorporate As Built
documentation for the various light use roads was submitted to the Division in late
December 2009, and is currently under review. If the revision is wholly or partially
approved prior to issuance of the SL-2 proposed approval, the Division may be able to
approve Phase I release for some or all of the light use roads labeled as "exclusions" within
the narrative and map Figures of this inspection report. The proposed permanent road
segments identified by the Division as "exclusions" from the Phase I bond release are delineated
on map Figures 1 and 2 of this report. Necessary documentation will need to be incorporated
into the approved permit prior to any future Phase 1 bond release request that would include the
subject road corridors. The status of proposed permanent road segments in the South Extension
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