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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 Rob Zuber, Dan Hernandez, and Jason Musick of the <br /> Colorado Division of Reclamation, Mining, and Safety(Division) on 20 April 2010. The purpose of the <br /> inspection was to evaluate the on-the-ground condition with respect to Trapper Mine's Phase I bond <br /> release application SL-11 in accordance with Rule 3.03.2(2). Graham Roberts of TMI accompanied <br /> the inspection. Also present were Christine Belka of OSM, Jennifer Maiolo of the BLM, and Lane <br /> Osborn of the Colorado State Land Board. <br /> Lands requested for liability release under SL-11 include 63.9 acres of land reclaimed in 2008. This <br /> includes 6.1 acres in two areas within block E-AB-08, 50.5 acres in two areas of F-AB-08, and 7.3 <br /> acres in three areas of Z-A-08. Surface land ownership is private (Trapper Mining Inc.) and State <br /> (Colorado State Land Board). Sub-surface ownership is both Federal and State. <br /> The weather was mostly sunny with clouds and a small amount of rain towards the end of the <br /> inspection. The ground was mostly dry during the inspection of the site with the exception of some <br /> muddy spots. All areas to be inspected were accessible and visible. <br /> Observed activity on site included a dragline (the Molly Brown) casting spoil in the K Ridge Pit above <br /> the Horse Gulch Fill site. Activity in Horse Gulch is progressing as permitted under TR-103. <br /> Roads <br /> All roads and roadside ditches were functioning as permitted at the time of the inspection with one <br /> exception. The road to D-Pit requires maintenance. At the time of the inspection, large ruts were in <br /> the middle of the road and drainage ditches were not well defined. <br /> Hydrologic Balance <br /> The contour ditches in bond release parcel F-AB-08 require repair as there are several blow-outs, and <br /> in some locations berms need repair in addition to the blow-outs. For example, as shown in the <br /> photograph below, at some locations berms have appeared to slump down the hill and need to be <br /> repaired with earth-moving equipment. <br /> Furthermore, one of the contour ditches does not drain properly and needs to be re-graded. A low <br /> spot in the middle of the ditch was observed, and this appears to have caused a blow-out. <br />