2010-12-10_REVISION - C1980007 (2)

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economically efficient manner, the perimeter of all areas affected by surface operations or facilities before beginning surface coal mining operations. Locations of, and distance between, markers will be determined by field conditions. While MCC will strive to erect markers at a frequency/spacing such that one marker is visible from the previous marker and the next, topography and other conditions/situations may not always allow nor require this. One such condition/situation would be an obvious visual contrast between a reclaimed area that has not achieved Phase III bond release and the surrounding undisturbed area. Under such a condition/situation, markers may not need to be visible from one to another. All erected perimeter markers will nevertheless be maintained through Phase III bond release." Let me know what you think, Kathy. Dan DaniefL Hernan&z Daniel I. Hernandez Senior Environmental Protection Specialist Colorado Division of Reclamation, Mining and Safety 1313 Sherman St, Room 215 Denver, CC 80203 New Phone Number: 303-866-3567 ext 8126 Fax: 303-832-8106 Website: www.minina.state.co.us From: Welt, Kathy [mailto:KWelt@archcoal.com] Sent: Tuesday, November 30, 2010 3:38 PM To: Hernandez, Daniel Cc: Brown, Sandy; Berry, David; Kaldenbach, Tom; Binns, Janet; Scott Wanstedt; Nolte, Doug; Sweetwood, Ryan Subject: RE: Perimeter Disturbance Markers Policy Dan, Thanks for the e-mail last month and for the response last week to Mountain Coal's MR-366 application. I will be submitting revised permit pages to reflect most of your suggestions, but I question one aspect of it. The rules on signs and markers (provided below) do not require that perimeter markers be retained and maintained until after phase 3 bond release - that's only required for mine I.D. signs (see highlight below). To keep markers maintained for 10 years on the upper side of a backfilled, re-graded and revegetated road or bench cut on the side of a mountain (like all of the West Elk Mine site), for instance, is very impractical and serves no purpose in ensuring that equipment operators know "where they can and can't disturb ground" (per Ms Belka below.) As is stated in Rule 4.02.4 the markers would be kept in place until the activities pertaining to the surface operations or facilities (e.g. vent fan, stockpiling, etc.) cease - i.e. during the operation of those facilities, but not after reclamation. As such, I am hesitant to commit to post-reclamation maintenance of markers in our DRMS permit. Thanks, Kathy "4.02.2 Mine'and Permit Identification Signs. (1) Identification signs shall be displayed at each entrance to the permit area from public roads. (2) Signs shall show the name, address, and telephone number of the person who conducts the surface coal mining operations and the identification number of the current permit authorizing mining activities. (3) Signs shall be retained and maintained until after the release of all bonds for the permit area.