_INSPECTION - C1981028 ‎(46)‎

• Permit No: C1981028
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 4/22/2010
• Email Name: RDZ
• 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.
This was a partial coal inspection conducted by Rob Zuber, Dan Hernandez, and Janet Binns of the
Colorado Division of Reclamation, Mining, and Safety(Division)on 22 April 2010. The mine no longer
extracts coal, but the remaining surface pit(Pit B) is permitted to receive flyash. The purpose of the
inspection was to evaluate the on-the-ground condition with respect to the Keenesburg Mine Phase II
bond release application SL-05 in accordance with Rule 3.03.2(2). Don MacDonald and Danny Kipp
of Coors Energy Company(CEC) accompanied the inspection. Also present was Mike Savage, a
consultant working for CEC, and Christine Belka of OSM. Representatives from Weld County and the
Colorado Land Board had been invited but did not attend the inspection.
Lands requested for liability release under SL-05 include 51 acres of land reclaimed between 1987
and 2003.
The weather was mostly cloudy but cleared towards the end of the inspection. The ground was wet
during the inspection. CEC recorded 0.57 inches of precipitation in the previous 24 hours. All areas
to be inspected were accessible by foot and visible. However(as discussed below), not all
sedimentology transects were accessed, but rather the areas adjacent to the transects were
accessed and the transect areas were observed from several hundred feet away.
Roads
All roads were inaccessible by truck at the time of the inspection due to recent rainfall.
Hydroloaic Balance
Although a significant amount of rain had fallen in the hours prior to the inspection (as noted above,
0.57 inches fell in the previous 24 hours), there was no water in either Pond 2 or The Dugout Pond.
Observation of sedimentology transects was conducted looking across the general area of the
transect locations. They were observed for general vegetative cover and approximate slope. Mr.
Savage confirmed that these transects were developed during the review of SL-03. The cover value
associated with the sedimentology transects was collected from the Osgood Sand Sage reference
area during SL-03. Photos of the sedimentology transects and the Osgood Sand Sage reference
area are shown below.
Topsoil
Prior to the inspection, DRMS staff reviewed previous documentation of topsoil (a.k.a. topsand)
measurement. Documents included photos and inspection reports. It was determined that
measurements of topsand at parcels 9, 19, and 29 had been conducted and documented in the past,
and topsand in these areas is sufficient. Topsand in the remaining areas of the SL-05 bond release
application was measured during the inspection using a hand auger, shovels, and measuring staff.
Holes were dug to at least 24 inches and the color and texture of the material was observed.
Topsand is predominantly sand and is distinctive from the spoil beneath, which contains more clay.
The topsand measurement effort is shown in the photos below. These photos show many of the
holes but not all of them. In most parcels, a hole was dug in the approximate center of the parcel.
Multiple holes were dug in parcels 6 and 10 due to their elongated shapes. Locations of the holes are
shown on the map below. In all parcels, the topsand was found to be at least 24 inches deep (see
table below), which is the requirement of the permit. The topsand application is in compliance with
the permit.