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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during <br />the inspection. Comments also describe any enforcement actions taken during the inspection and the <br />facts or evidence supporting the enforcement action. <br />This was a complete inspection conducted by Janet Binns and Rob Zuber of Colorado Division of <br />Reclamation, Mining and Safety. Mr. Roy Karo of HGTI provided access to the records located at the <br />HGTI/Seneca Coal Co. office, located at the load out. The site is an inactive load-out. The operation is <br />approved to operate as a load-in facility too, but construction of off loading structures has not <br />commenced. Weather was clear and cold (-0 degrees F) with approximately 12-24 inches of snow on <br />the ground. Snow shoes were used to access the facilities area. <br />Dennis Jones provided an envelope to take to Sandy Brown of DRMS. <br />Records: Records for the Load Out were checked at the HGTI office. The Air Emissions permit has <br />expired (8/23/2008). Since no loading or unloading activity is occurring on the site, the operator will <br />wait until the operation is planned to reactivate prior to obtaining a new emission permit. This is <br />acceptable with DRMS. Records are complete and up to date. <br />Hydrologic Balance: The load out site was snow covered. Ditches were snow covered and not visible. <br />The truck loop pond (Pond 1) was snow covered below the discharge riser elevation. The rail loop pond <br />(Pond 2) was snow covered. Area is frozen and no runoff was occurring. No concerns were identified. <br />Support facilities: The facilities area is idle with no new activity occurring on site since the November <br />inspection. <br />No maintenance items were identified other than updating of the records. <br />3 of 5 WHITE - File YELLOW - Operator PINK - Specialist