INSPEC12710

• Permit No: C1982057
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 11/18/2003
• Media Type: D
• Archive: No

III. COMMENTS -COMPLIANCE
Below are comments on the inspection. The comments include discussion of observations made
during the inspection. Comments also describe any enforcement actions taken during the inspection
and the facts or evidence supporting the enforcement action.
which is to be extensively roughened and broadcast seeded due to the average slope
gradient that exceeds 25%. Attempts had been made to roughen the slopes during the
period of inspection, first with a D-5 dozer and later with a D-8 dozer, but the work was
hampered by wet surface soil conditions. The project had not been completed by the
conclusion of the inspection. The reclamation schedule of the approved permit specifies
completion of topsoiling, seedbed preparation and seeding in the "D" Pit area by the end of
the fall 2003 field season. If the required work cannot be safely and properly completed
due to weather and soil conditions, an enforcement action may be warranted.
At the "B" Pit area, a five scraper fleet was hauling soil from stockpile and placing the soil
along the base of the steep south facing slope to the north and east of the final "B" pit cut.
This slope was stripped of topsoil years ago in preparation for temporary spoil stockpiling
that never occurred. The operator had anticipated completion of topsoiling and revegetation
on these slopes in 2003, but it does not appear that the approved reclamation schedule
specifically requires that the topsoiling and revegetation be completed in 2003. Based on
site conditions at the time of the inspection and snowfall that began on Saturday November
22 immediately following the inspection (email from Roy Karo), it appears unlikely that
topsoil and revegetation will be completed on the slopes. Due to the steep gradients,
extensive soil roughening and broadcast seeding will be required. The topsoiling,
roughening and seeding will need to be conducted in conjunction with topsoiling and
revegetation of adjacent "B" Pit and lower "A" Pit areas during 2004.
In the lower "A" Pit area (generally below the powerline), and the remaining "B" pit and
spoil, backfilling and grading is continuing and is to be completed during 2003. Topsoiling,
final drainage construction, and revegetation will be required during 2004.
The middle section of the "A" Pit area (generally between the powerline and the ridgeline
access road was regraded in 2002. As such, the approved plan requires that the entire area
be topsoiled and reseeded in 2003. Portions of this 40 acre area were topsoiled and
seeded, but other areas were not, including graded spoils to the west of the aspen test
plots, and the north facing highwall reduction slopes. It appears unlikely that topsoiling and
seeding will be accomplished in these locations this year, and enforcement action may be
warranted. Due to steep gradients of the highwall reduction slopes in both the middle and
lower sections of the "A" Pit area, it would appear that extensive soil roughening and
broadcast seeding will be required following soil replacement.
Topsoil stripping operations appear to have been properly completed this summer and fall in
advance of pit development and associated operations associated with the Wadge and Sage
Creek/Wolf Creek mining areas in the South Extension portion of the permit area, as well as
the Haul Road "K" corridor.