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Please see the emails below that summarize the interpretation for, the perimeter disturbance markers. OSM has <br />confirmed the interpretation Dan H. and I discussed yesterday. This interpretation is consistent with how we have <br />applied the marker requirements at the mines on my team. I don't see any conflict with the perimeter makers and <br />signage that Mountain Coal Company has proposed in their email to Dan. A revision to the Deserado permit will be <br />necessary to require perimeter markers on the large, extended long-term mine facilities. <br />I think we can put this issue to rest. <br />Sandy <br />From: Belka, Christine <br />Sent: Thursday, October 14, 2010 8:33 AM <br />To: 'Brown, Sandy'; Shaeffer, Elizabeth A. <br />Subject: RE: Disturbance Markers <br />Hi Sandy, <br />Yes, I believe you have captured my concerns. My thought on the subject is that the markers are intended to tell <br />equipment operators where they can and can't disturb ground. Main facilities areas are long-term disturbances where <br />equipment and stockpiles are regularly moving around. Keeping those areas delineated helps inspectors see if <br />boundaries are being pushed. Once constructed, MDW don't tend to have a lot of earth moving equipment on site. For <br />that reason, I would be ok with allowing those markers to be removed before final bond release. Ultimately, it is up to <br />you - whatever you think serves you and the intent of the regulation best. My other concern is consistency. After we left <br />Deserado, mine staff contacted several other operations and the Utah regulatory program to see how the regulation is <br />enforced elsewhere. <br />Thank you so much for your attention to this issue. <br />Christine <br />From: Brown, Sandy [mailto:Sandy.Brown@state.co.us] <br />Sent: Wednesday, October 13, 2010 11:20 AM <br />To: Belka, Christine; Shaeffer, Elizabeth A. <br />Subject: Disturbance Markers <br />Hi Christine and Elizabeth, <br />I believe the following summary reflects the concerns OSM has with respect to disturbance markers. Please let me know <br />if I have accurately described the concerns so that we can move on with this issue. <br />Your primary concern is that OSM did not observe any disturbance area markers at the Deserado Mine either at the <br />facilities or methane degas well sites on their complete inspection. The lack of markers at Deserado is allowed by the <br />permit. However, according to Dan H. when Jason returned for another inspection, Deserado had installed some <br />markers; Dan and Jason will ask Deserado to revise the permit to require disturbance area markers until final bond <br />release for the major facility areas. <br />Another concern is whether markers are needed at methane degas well sites until final bond release. After discussing <br />the difficulties with maintaining markers around methane degas well sites, OSM agrees that MDW sites should be <br />marked, or staked, prior to disturbance, however it is impractical to require that markers be maintained in these remote <br />areas until final bond release. <br />Thanks,