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marked during the conduct of all activities to which they pertain until final bond release. <br />Perimeters markers will not be required to demarcate approved surface disturbance boundaries <br />associated with short-term operations/facilities such as methane drainage wells, though the <br />approved boundaries of these short-term disturbances may be temporarily marked with survey <br />stakes, laths or flags." Please note that this proposed language is simply a suggestion, but <br />a suggestion that I believe addresses both OSM's and Blue Mountain's concerns. <br />Thank you both for your input, and for your patience. Please feel free to call me with any <br />further questions or comments you may have. <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: Brown, Sandy <br />Sent: Thursday, October 14, 2010 12:36 PM <br />To: Hernandez, Daniel; Berry, David <br />Subject: FW:Perimeter Disturbance Markers <br />Dave and Dan, <br />Please see the emails below that summarize the interpretation for the perimeter disturbance <br />markers. OSM has confirmed the interpretation Dan H. and I discussed yesterday. This <br />interpretation is consistent with how we have applied the marker requirements at the mines on <br />my team. I don't see any conflict with the perimeter makers and signage that Mountain Coal <br />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 <br />are intended to tell equipment operators where they can and can't disturb ground. Main <br />facilities areas are long-term disturbances where equipment and stockpiles are regularly <br />moving around. Keeping those areas delineated helps inspectors see if boundaries are being <br />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 <br />release. Ultimately, it is up to you - whatever you think serves you and the intent of the <br />regulation best. My other concern is consistency. After we left Deserado, mine staff <br />contacted several other operations and the Utah regulatory program to see how the regulation <br />is enforced elsewhere. <br />Thank you so much for your attention to this issue. <br />6