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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 />Sediment Pond 6 contained a shallow pool, frozen over, in the deepest portion of the pond. Perimeter <br />containment ditches were properly maintained and functional. Upper sections of the perimeter ditches that <br />are not currently riprapped will need to be graded and riprapped in accordance with permit design in <br />association with final reclamation soil cover placement on the adjacent mine benches. <br />Wild horse spoor was prevalent on the reclaimed portions of CRDA-I and adjacent reclaimed areas. At the <br />reclaimed stockpile site dvectly east of CRDA-I, a high percentage of the perennial bunchgrasses had been <br />grazed off near ground level, and some trampling damage to 4-wingsaltbush shrubs was evident. <br />Cameo Soil Borrow Area-2 <br />Pond 11 was dry, with no evidence of recent inflow. Pond bottom was approximately 8 feet below the <br />spillway elevation. <br />A small portion of the CBA-2 borrow area was previously stripped of topsoil, but underlying borrow soil <br />was not excavated. Interim stabilization seeding of this area in 1994 was quite successful, and it now <br />blends in quite well to the native vegetation on the remainder of the borrow area from which topsoil has not <br />yet been stripped. Stripped areas can be distinguished from non-stripped areas based on dominant <br />vegetation species (four-wingsaltbush on stripped vs. greasewood on native), presence of weathered <br />sandstone boulders with lichen on native, and the presence of a perimeter collection ditch between the <br />stripped area and the channel of Coal Gulch. <br />The topsoil stockpile sign on the stockpile at (he west end ojthe borrow area has been shot up to the poin! <br />tha! i! is no Jonger legible, and should be replaced <br />CRDA-2 and adiacent areas <br />The top of CRDA-2 has been graded and compacted, and construction of the new upper diversion ditch has <br />been initiated, as described in the inspection report issued October 29, 2001. There was evidence of <br />relatively recent water flow from some areas on top of the pile (apparently from water truck dust spray <br />operations), that caused Tilling in several locations down the upper bench outslope to the terrace drain <br />below. Grading ojthis slope and segments ojlhe upper terrace drain (rJ4J will be necessary prior to cover <br />soil placement. The eastern terminus ojTerrace Drain#4 needs !o be worked prior to cover placement, !o <br />repair rills and to better define the drain (o the perimeter ditch a! design grade. Upper perimeter ditch <br />riprap ins(allation is !o be completed in association with Erna! cover soil placement. <br />Existing perimeter ditches and the existing upper diversion ditch were in general properly maintained and <br />functional. Only one item of concern was noted, a 12"diameter hole in the bottom of the upper diversion <br />ditch, approximately 90 yards from the west end of the diversion, which appeared to be at least 2 feet deep, <br />possibly deeper. The hole needs !o be filled in. <br />The operator conducted supplemental broadcast interseeding of native shrubs and grasses on CRDA-2 <br />reclaimed slopes earlier this fall, in an effort to enhance diversity of the stand, which over much of the pile <br />is heavily dominated by four-wingsaltbush. The fluffy seeds ofgalleta, winterfat, and rubber rabbitbrush <br />were readily apparent on the reclaimed slopes. <br />