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<br />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 <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a partial, special focus inspection conducted jointly by <br />Dan Mathews of DMG and Henry Austin of OSM. The inspection focus <br />was contemporaneous reclamation and the inspection was limited to <br />the coal waste disosal areas. The inspection began at <br />approximately 7:15 a.m., at the reclaimed Refuse Area No. 1 (RA-1). <br />The perimeter and interior areas of RA-1, RA-2/3, RA-4, and RA-5 <br />were walked, and various issues relating to contemporaneous <br />reclamation were discussed. Weather was partly cloudy to clear, <br />and warm. Site conditions were dry; Ponds RP-1, RP-4, and RP-5 <br />were dry, while RP-2/3 water level was several feet below the top <br />of the primary spillway riser. The inspectors were accompanied by <br />Gordon Bell of Western Fuels-Utah (WFU). The inspection concluded <br />at approximately 11:30 a.m. <br />RA-1 <br />RA-1 was covered with 4 feet of suitable subsoil and topsoil, and <br />reseeded in the fall of 1990. Cover depth test plots ranging from <br />1 to 4 feet of cover over refuse were established on north facing <br />and south facing slopes of the refuse area, as part of a 5 year <br />study to evaluate the required cover depth for the remaining refuse <br />areas at Deserado. WFU submitted the refuse cover final report in <br />January, 1996, and a review of the report was issued by the <br />Division in June, 1996. Additional soil sampling to evaluate the <br />extent of any upward diffusion of salts from the refuse into the <br />cover soil was requested by the Division. The soil sampling and <br />analysis is to be conducted this field season, and the results will <br />be an important component of any requested reduction in the four <br />foot cover depth requirement. <br />Observations made during the inspection were that both the <br />reclaimed slopes and permanent perimeter ditches appeared to be <br />stable, with no evidence of surficial erosion or slumping. A <br />fairly dense ground cover was noted throughout the refuse pile, but <br />throughout much of the site, particularly the relatively flat top <br />of the pile, the cover consisted almost exclusively of standing <br />dead cheatgrass and tumble mustard remaining from the 1995 growing <br />season, with lesser growth of these annual weedy species from the <br />1996 growing season. Several perennial wheatgrasses, green <br />needlegrass and Russian wildrye are present in scatttered areas, <br />with fair establishment on north and west facing slopes, poor to <br />fair establishment on the south facing slopes, and poor <br />establishment elsewhere. Very few seeded shrubs or forbs have <br />established anywhere on the pile. It would appear that vegetation <br />