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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 d'vring the inspection <br />and the facts or evidence supporting the enforcement action. <br />Final reclamation of the permanent diversion will be implemented in conjunction with <br />removal of Sediment Ponds 6 and 10. The proposed final permanent channel segment will <br />include an "S" curve through the area now occupied by Pond 6, in the approximate original <br />channel location. This design is included in TR-42, currently under review. <br />The interim channel segment was certified following completion IP.E. certification dated <br />6/21/02). The segment has experienced some scour since completion, and there has been <br />some under-cutting of the riprap bank protection that will need to be monitored. Repair will <br />be necessary if the installation is compromised. <br />Coa/ Creek Vicinity <br />Various support facilities adjacent to the Coal Creek permanent diversion segment were <br />reclaimed in 2002, including soil borrow area CBA-1, and Topsoil Storage Areas 7 and 9. <br />Sediment control berms, ditches, and sediment traps will be reclaimed upon demonstration <br />of adequate vegetation establishment, most probably in conjunction with reclamation of <br />Sediment Ponds 6 and 10. <br />Coal Processing Waste <br />CRDA-2 <br />Refuse Area CRDA-2 was fully reclaimed in 2002. The lower three benches of the pile had <br />been permanently reclaimed in 1994. The upper two benches were final graded, cover- <br />soiled, seeded and mulched in April 2002. The final reclamation project in spring 2002 <br />included the construction of a new permanent upper diversion ditch, and riprap installation <br />along the upper segment of the East Perimeter Ditch. Final reclamation included extensive <br />roughening to enhance vegetation establishment, and rock placement for small animal <br />habitat. In November 2002, the old upper diversion ditch located on the steep canyon <br />sideslope above the pile was regraded and revegetated, as was the temporary access road <br />up the face of the pile. <br />DMG documented compliance of the lower reclaimed benches and perimeter ditches during <br />a special focus oversight inspection conducted with OSM in August 1997. Extensive slope <br />and ditch measurements were taken, and results were described in the DMG inspection <br />report of August 29, 1997 and report addendum of October 17, 1997. <br />Adequate soil cover thickness (24") on the lower benches was documented in DMG <br />inspection reports of June 29, 1994 and June 8, 1995. Adequate soil cover thickness on <br />the upper benches (top of pile and side slopes) was documented in DMG inspection report <br />of January 31, 2003. <br />Construction certification for the new upper diversion ditch is included in the 3rd quarter <br />2002 refuse area P.E. certification by Jim Stover. Construction certification of the newly <br />constructed segment of the east perimeter ditch is included in the same refuse certification <br />report. DMG measurements of the new perimeter ditch segment are documented in the <br />