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111. 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 d~uing the inspection <br />and the facts or evidence supporting the enforcement action. <br />3) Please address the apparent inconsistency between permit text and Exhibit 26, with <br />regard to RSRDA terrace drain width, and amend the permit as appropriate. Please address <br />the inconsistency and amend the permit prior to the Phase I bond release inspection. <br />Revegetation/Reclamation Success <br />Seeded vegetation had not yet germinated on areas revegetated in November 2002. <br />Perennial grasses and widely scattered seedling shrubs germinated in the fall of 2002 on <br />areas revegetated in Aprif 2002, along with significant volunteer of annual wheat from seed <br />in the straw mulch. No germination of species interseeded on older revegetation areas of <br />CRDA-2 in the fall of 2001 was apparent. It is too early to evaluate success of these <br />recent seeding efforts. <br />Outlying areas seeded in 2000 and 2001 included portions of the North Decline Area (Ute <br />Water Corridor), as well as disturbed areas at the South Fan and Borrow Area and 2West <br />Portals. Initial establishment of grasses and shrubs appears promising in most areas, <br />although establishment is relatively sparse on the steep upper portions of backfilled slopes <br />at the 2West Portals. <br />Of the permanent reclamation areas seeded in 1994 or earlier, CRDA 1 supports a diverse <br />cover of grasses and shrubs, with a scattering of perennial (orbs, and represents the most <br />successful of the older seeded areas. At CRDA-2, slopes appear stable, but large areas of <br />the pile are dominated by four wing saltbush, with minimal perennial understory and low <br />diversity. Interseeding was conducted in 2001 due to the documented low diversity of the <br />stand. At the North Decline Area, there are good numbers of fourwing saltbush and <br />greasewood over most of the site, but perennial understory is spotty with a significant <br />cheatgrass component, which is fairly typical of upland greasewood habitats in the general <br />area. Slopes in the area are gentle, with no indications of erosional instability. <br />Refuse Area Slope and Terrace Drain Measurements and Compliance <br />Evaluation <br />Transects were run on refuse area outslopes along the fall line to estimate slope gradients <br />of the benches reclaimed in 2002. Grade was estimated using an abney level, sighting <br />point on assistant based on eye level of recorder (e.g. 5'7"). Slope distance was measured <br />with a 300 foot tape. Bench height was later calculated by conversion of slope % to <br />degrees and application of trigonometric formula [Sin A =a/c, where A=angle measured in <br />degrees, c=measured slope in feet (hypotenuse), and a=bench height in feet]. Terrace <br />drain widths were measured along each transact. Estimated slope gradients, measured <br />terrace drain widths, and calculated bench heights are presented on the following Tables for <br />CRDA-1, CRDA-2, and RSRDA. Approximate transect locations and orientations are <br />depicted on the aerial photos attached to this inspection report. <br />12 <br />