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(though it has been DRMS's practice to ask operators to erect perimeter markers such that <br />they are visible from one marker to the next). <br />MCC may therefore wish to consider proposing permit text that states something like "MCC will <br />clearly mark, in an economically efficient manner, the perimeter of all areas affected by <br />surface operations or facilities before beginning surface coal mining operations. Locations <br />of, and distance between, markers will be determined by field conditions. While MCC will <br />strive to erect markers at a frequency/spacing such that one marker is visible from the <br />previous marker and the next, topography and other conditions/situations may not always allow <br />nor require this. One such condition/situation would be an obvious visual contrast between a <br />reclaimed area that has not achieved Phase III bond release and the surrounding undisturbed <br />area. Under such a condition/situation, markers may not need to be visible from one to <br />another. All erected perimeter markers will nevertheless be maintained through Phase III <br />bond release." <br />Let me know what you think, Kathy. <br />Dan <br />Daniel I. Hernandez <br />Daniel I. Hernandez <br />Senior Environmental Protection Specialist Colorado Division of Reclamation, Mining and <br />Safety <br />1313 Sherman St, Room 215 <br />Denver, CO 80203 <br />New Phone Number: 303-866-3567 ext 8126 <br />Fax: 303-832-8106 <br />Website: www.mining.state.co.us<http://www.mining.state.co.us> <br />From: Welt, Kathy [mailto:KWelt@archcoal.com] <br />Sent: Tuesday, November 30, 2010 3:38 PM <br />To: Hernandez, Daniel <br />Cc: Brown, Sandy; Berry, David; Kaldenbach, Tom; Binns, Janet; Scott Wanstedt; Nolte, Doug; <br />Sweetwood, Ryan <br />Subject: RE: Perimeter Disturbance Markers Policy <br />Dan, <br />Thanks for the e-mail last month and for the response last week to Mountain Coal's MR-366 <br />application. I will be submitting revised permit pages to reflect most of your suggestions, <br />but I question one aspect of it. The rules on signs and markers (provided below) do not <br />require that perimeter markers be retained and maintained until after phase 3 bond release - <br />that's only required for mine I.D. signs (see highlight below). To keep markers maintained <br />for 10 years on the upper side of a backfilled, re-graded and revegetated road or bench cut <br />on the side of a mountain (like all of the West Elk Mine site), for instance, is very <br />impractical and serves no purpose in ensuring that equipment operators know "where they can <br />and can't disturb ground" (per Ms Belka below.) As is stated in Rule 4.02.4 the markers <br />would be kept in place until the activities pertaining to the surface operations or <br />facilities (e.g. vent fan, stockpiling, etc.) cease - i.e. during the operation of those <br />facilities, but not after reclamation. As such, I am hesitant to commit to post-reclamation <br />maintenance of markers in our DBMS permit. <br />Thanks, <br />Kathy <br />"4.02.2 Mine and Permit <br />(1) Identification signs <br />roads. <br />Identification Signs. <br />shall be displayed at each entrance to the permit area from public <br />4