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July 19, 2011 C-1980-007/West Elk Mine TAK <br /> is provided behind a tab in Exhibit 80 of the permit application that corresponds to the MR or TR in which that <br /> group o f MDWs and roads were approved. <br /> The reclamation plan for MDW pads generally has the following three steps: <br /> 1. Upon completion of each phase of activity at a given site,all debris,trash,and drilling related equipment, or de- <br /> gas housing will be removed from the site. <br /> 2. When the mud pit or pits are sufficiently dry,they will be filled with stored soil material and compacted to <br /> minimize any settling. <br /> 3. A backhoe and a bulldozer will redistribute material on and around the drill pad to achieve as closely as <br /> practicable the original contour of the site. The area will then be ripped or scarified. <br /> The reclamation plan calls for MDW access roads to be restored as closely as possible to the approximate original <br /> contour with an uneven final surface. <br /> In an email from Tom Kaldenbach to Ryan Sweetwater,dated January 25, 2011,DRMS notified Mountain Coal <br /> Company that approximate original contour would be verified during this inspection by visual observation because <br /> of: <br /> a)the small sizes of the disturbed areas(most drill pads are less than one acre), and <br /> b)the material that was regraded to achieve approximate original contour was stockpiled on each site. <br /> The email explained that if achievement of approximate original contour for a site is in question,then DRMS may <br /> request submittal of additional information, including detailed topographic profiles and topographic maps. <br /> Mike Ward,the operator's consultant,has a detailed knowledge of the bond release area,having prepared <br /> reclamation progress reports (Annual Reclamation Photograph Project Reports)for the West Elk Mine each year <br /> since 2004. These reports contain photographs of each site in the bond release area,providing year-by-year <br /> comparisons of ground conditions. The West Elk Mine prepares these reports on their own initiative. Mr. Ward's <br /> participation in the inspection greatly expedited finding the remote sites and he provided a valuable historical <br /> perspective on reclamation progress. <br /> During the inspection,the ground was dry and the weather was clear and warm. Of the 55 individual disturbed <br /> sites in the bond release area, approximately 35 were visited. Three sites sites could be seen from across Deep <br /> Creek and the remainder have been visited on past inspections. All sites appeared very similar to the photographs <br /> in the 2010 Annual Reclamation Photograph Project. <br /> The inspection checked wellbore locations on the ground surface for compliance with Rule 4.07.3 which requires <br /> that wellbore closures be designed to prevent access to the mine workings and to keep acid other toxic drainage <br /> from entering ground or surface waters. 4.07.3 also requires a hole to be marked. <br /> Number of Partial Inspection this Fiscal Year,ending 6/30/12: 1 <br /> Number of Complete Inspections this Fiscal Year: 0 <br /> Page 3 of 11 <br />