INSPEC16765

• Permit No: C1981041
• IBM Index Class Name: Inspection
• Doc Name: OSM Inspection Report
• Inspection Date: 6/17/2004
• Media Type: D
• Archive: No

ROADSIDE MINE
On June 17, 2003, OSM and DMG visited the Roadside Mine, Snowcap Coal Company,
Inc., Permit No, C-81-041. Tonya Hammond, Snowcap's local consultant with Stover
and Associates, also attended the evaluation. Three coal waste banks were evaluated for
reclamation success and off-site impacts. The three banks are Cameo Refuse Disposal
Area (CRDA) -1, CRDA-2, and the Roadside Waste Bank.
CRDA-1
This coal waste bank consisted of three lower benches and two upper benches. Both the
topsoil and subsoil cover material came from a borrow area north and west of CRDA-1.
The topsoil/subsoil depth of CRDA-1 is 18 inches, which is required in the approved
permit application. The DMG approved a variance from the requirement at Rule
4.10.4(5) that waste banks be covered with a minimum of four feet non-toxic and non-
combustible material following amulti-year field trial and prior to initial reclamation in
1994. The variance was granted due to the aspect of the slope, the lack of available cover
material, and a study conducted by the Roadside Mine that demonstrates 18 inches of
topsoil/subsoil is adequate for revegetation purposes. Thus, the topsoil/subsoil has been
replaced to required depths in accordance with Rule 4.06.4(2). The permit contains
specifications for higher quality soil [lower levels of conductivity (salinity) and sodium
absorption ratio {SAR) in the top six inches]. Sampling conducted by the operator has
indicated that the replaced topsoil and subsoil horizons are largely indistinguishable from
one another, and in some Locations the topdressing quality criteria were exceeded.
Vegetation establishment on these areas will be closely watched during the first few
growing seasons, and mitigative measures will be required by DMG if warranted.
Consistent with Rule 4.06.5, the topsoil has been redistributed and "roughened," or
gouged, with a track hoe to catch moisture.
Because of the arid environment and nature of the parent materials in the permit area,
soils typically have elevated levels of salts and high sodium absorption ratios. Native
vegetation communities and the species included in the approved permanent seed mixes
are adapted to these conditions. As a result, some spotty establishment may result. The
seed mix consists of different grass species and shrubs including shadscale saltbush,
greasewood, snakeweed, wheat grass, wild rye and four-wing saltbush. The vegetation is
conducive to a salt desert habitat. The lower benches were reclaimed and seeded in 1994.
Reclamation of the upper benches began in February of 2002 and the banks were seeded
in April of that year. However, due to dry conditions, there was no germination in the
spring or summer of 2002, so this is the first full growing season for the upper benches.
Some germination occurred in the fall of 2002, with additional germination and growth in
the spring of 2003. In accordance with Rule 4.15.3(1), seeding and planting of replaced
topsoil was conducted during the first normal period for favorable planting conditions
after final preparation for seeding or planting. Moreover, consistent with Rule 4.15.4
which requires that soil stabilizing practices be carried out, heavy mulching has occurred
on all terraces and has resulted in the growth of some wheat in various areas. The
seeding of perennial vegetation has resulted in very good establishment in all areas where
there was a heavy growth of volunteer wheat. The wheat acts as a nurse crop providing