2012-06-29_INSPECTION - C1980007 (2)

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June 19, 2012 C -1980- 007 /West Elk Mine JRS BACKFILL and GRADING — Rule 4.14 Contemporaneous Reclamation 4.14.1; Approximate Original Contour 4.14.2; Highwall Elimination 4.14.1(2)(f); Steep Slopes 4.14.2,4.27; Handling of Acid and Toxic Materials 4.14.3; Stabilization of Rills and Gullies 4.14.6: - While this inspection primarily focused on Phase II Bond Release criteria, the overall stability of the backfilled and regraded areas is still important and taken into account during a Phase II Bond Release. None of the approximately 33 sites, including MDW pads and roads, the thermal event area pads and roads and the lone Pine Gulch facilities areas showed any signs of cracking, settling or slumping. all of the sites were stable and well vegetated, with no erosional problems noted. Please see the Reclamation Success section below for detailed information regarding each location. FISH and WILDLIFE — Rule 4.18: - Aside from ground squirrels and birds, no wildlife was observed on the reclaimed sites at the time of the inspection. There were, however, signs of large game mammals on virtually all of the sites. These sign included bear, elk and coyote scat and bear, elk and coyote tracks. there was also evidence of bears overturning large logs on the reclaimed roads to get to ant hills under the logs. Based on these observations, it appears as though there is extensive wildlife use on these reclaimed sites. ROADS — Rule 4.03 Construction 4.03.1(3)/4.03.2(3) Drainage 4.03.1(4)/4.03.2(4) Surfacing and Maintenance 4.03.1(5) and (6)/4.03.2(5) and (6) Reclamation 4.03.1(7)/4.03.2(7): - There were several roads that are still in service (not reclaimed) that are used to access the reclaimed road spurs and pads and active drilling. These roads include the Jumbo Mountain Road, West Flat Iron Road, Long Draw Saddle Road and the Old Road. All of these roads were well maintained and stable and no erosional problems were noted on the roads. The roads were very dry and dusty at the time of the inspection. We also drove along Forest Service Road 711, which was somewhat rutted due to the road's multiple uses. This road was, however, generally stable and in good condition. It, too, was very dry and dusty. RECLAMATION SUCCESS - Rule 4.15, Rule 3: - The first area inspected was the reclaimed Upper Deep Creek Road, Deep Creek Mesa Road and the reclaimed 96 -36 -1 drill pad. The reclaimed roads and pad were approximately 8.8 acres of disturbance and were reclaimed in 2004. The roads and pad were all stable, with no erosional problems noted. There was good cover on both the roads and the pad and shrubs, including chokecherry, snowberry, oak brush and, in some places, sagebrush, were beginning to grow on the reclamation (even though they were not a part of the seed mix). Dominant grass and forb species included western wheatgrass, mountain brome, Kentucky bluegrass and yarrow. There were scattered Canada thistle on the reclaimed roads and a larger patch (approximately 1/4 acre) on the drill pad. There was also some hound's tongue seen on the roads. These weeds will need to be sprayed and monitored. Overall, the reclamation on the Upper Deep Creek Road, Deep Creek Mesa Road and the reclaimed 96 -36 -1 drill pad was very good. Number of Partial Inspection this Fiscal Year: 12 Number of Complete Inspections this Fiscal Year: 4 Page 3 of 31