2010-12-10_REVISION - C1980007 ‎(2)‎

• Permit No: C1980007
• IBM Index Class Name: REVISION
• Doc Date: 12/10/2010
• Doc Name: Extension Request and Approval ‎(Emailed)‎
• From: Dan Hernandez
• To: Kathy Welt
• Type & Sequence: MR366
• Email Name: TAK
• Email Name: JRC
• Email Name: DIH
• Media Type: D
• Archive: No

4.02.3 Perimeter Markers.
The perimeter of a permit area for surface coal mining activities, or in the case
of underground mining activities, the perimeter of all areas affected by surface
operations or facilities, shall be clearly marked before the beginning of surface
coal mining operations.
4.02.4 Duration of Maintenance.
Signs and markers shall be maintained during the conduct of all activities to
which they pertain."
Cathy Weft,
Environmental Engineer III
Mountain Coal Company, LLC
West Elk Mine
P.O. Box 591
Somerset, CO 81434
Phone [phone]
Cell [phone]
Fax [phone]
From: Hernandez, Daniel [mailto:[e-mail]]
Sent: Thursday, October 14, 2010 2:33 PM
To: Scott Wanstedt; Welt, Kathy
Cc: Brown, Sandy; Berry, David; Kaldenbach, Tom; Binns, Janet
Subject: RE: Perimeter Disturbance Markers Policy
Dear Scott and Kathy-
I'm forwarding an e-mail from Sandy Brown regarding resolution with OSM of issues pertaining to perimeter markers at
underground mines raised during last year's Oversight Evaluation Year.
Kathy - We will now proceed with finalizing our review of MR-366 to the West Elk Mine permit in accordance with
Sandy's e-mail. As you can see, perimeter markers will now be required at underground coal mines to mark the
perimeter of only those areas associated with long-term operations or facilities. Perimeter markers will need to be
erected at long-term operations/facilities before surface disturbances associated with those operations/facilities begin,
and will need to be maintained until those surface disturbances are granted Phase III bond release. Perimeter markers
will not be required to demarcate approved surface disturbance boundaries associated with methane drainage wells;
however, Mountain Coal Company's current practice of utilizing 6" X 12" signs to denote locations of MDW sites for the
benefit of DRMS inspectors, MCC personnel, and the public is exemplary, so we will suggest in our review of MR-366
that MCC continue this practice.
Scott - Current language in the Deserado Mine permit at Section IV.K "Signs and Markers" states that markers were
placed around Deserado's permit boundary, and further states that boundaries of long-term disturbances are to remain
marked until such time as the extent of the disturbance is complete. Blue Mountain Energy should now submit a Minor
Revision to the Deserado Mine permit to (1) remove references in the permit to markers being placed around the mine's
permit boundary, and (2) revise existing language so as to state something along the lines of "the perimeter of areas to
be affected by long-term operations or facilities will be clearly marked before the beginning of surface coal mining
operations and will remain marked during the conduct of all activities to which they pertain until final bond release.
Perimeters markers will not be required to demarcate approved surface disturbance boundaries associated with short-
term operations/facilities such as methane drainage wells, though the approved boundaries of these short-term
disturbances may be temporarily marked with survey stakes, laths or flags." Please note that this proposed language is
simply a suggestion, but a suggestion that I believe addresses both OSM's and Blue Mountain's concerns.