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III. COMMENTS - COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made <br /> during the inspection. Comments also describe any enforcement actions taken during the inspection <br /> and the facts or evidence supporting the enforcement action. <br /> This was a partial inspection conducted by Kent Gorham of the Colorado Division of <br /> Reclamation, Mining, and Safety (Division). The inspection was conducted jointly with <br /> representatives of the Office of Surface Mining (OSM) for the purposes of conducting a special <br /> focus inspection as required by the Oversight Evaluation Year EY2011 Plan (the plan). <br /> Representing the OSM were Howard Strand and Christina Hulsman. Ron Thompson, Al <br /> Weaver, and Bobby Steele represented New Elk Coal Company (NECC) during various <br /> portions of the inspection. Ground conditions were very dry and the weather was warm and <br /> windy. <br /> The Special Focus topic as defined in the plan for this site was "prevention of off-site impacts, <br /> Small Area Exemptions". While the term "small area exemption (SAE)" is not defined in the <br /> Colorado regulations governing coal mining, exemptions from the requirement for all surface <br /> drainage to pass through a sediment pond are allowed under Rule 4.05.2(3) as long as the <br /> operator can demonstrate that sediment ponds or treatment facilities are not necessary for the <br /> drainage to meet effluent limitations, there is no mixing with discharge from an underground <br /> mine, and the area is small. <br /> The inspection began at the New Elk Coal Company office at 2 pm on Monday, June 6, 2011. <br /> OSM and Division personnel reviewed permit documentation for 14 SAE's within the current <br /> New Elk Mine site boundary including the coal loadout on the western edge of Trinidad, <br /> Colorado. Documentation reviewed included approved permit application (PAP) text narrative, <br /> SEDCAD sediment modeling documentation in Exhibit 19 of the PAP, and various figures and <br /> maps, generally showing location related information of the SAE's. The inspection continued <br /> during normal business hours until completion at about 12:15 pm Wednesday, June 8, 2011. <br /> Signs and Markers <br /> Disturbed area markers as required by Rule 4.02.3 were noted in all cases where the disturbed <br /> area boundary was proximate to an SAE area, including the two Apache Canyon ventilation fan <br /> sites, the coal loadout area, the west portal pumphouse area, and the west portal water tank <br /> area. <br /> Hydrologic Balance <br /> Fourteen SAE's are approved under the current New Elk mine permit. <br /> • West Portal substation <br /> • West Portal Water Tanks Area 1 <br /> • West Portal Water Tanks Area 2 <br /> • West Portal Core House <br /> • East Portal Water Tanks <br /> • West Portal Pumphouse Area <br /> • Contaminated Topsoil Area <br /> • Topsoil Pile #2 and Bates Portals Topsoil and Subsoil SAE <br /> • East Side of the Development Waste Pile <br /> 3 <br />