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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 />This was a partial mine site inspection conducted by Dan Mathews of DMG, accompanied <br />by Scott Wanstedt of BME. Areas inspected included the reclaimed East Portal Ventilation <br />Entry and access road, the "D" Portal Area, Refuse Areas, and Slot Storage Area. Weather <br />was clear and warm and ground conditions were dry. <br />Roads <br />The mine access road and refuse haul road appeared to be properly maintained, with <br />surface treatment adequate to control dust and no evident erosion of road cuts or fills. <br />Hydrologic Balance <br />The summer has been very dry. Refuse area sediment ponds were dry. Sediment Pond DP- <br />1 was discharging a few gpm, discharge water was clear. Small area exemption silt fencing <br />and berms at the reclaimed East Portal Ventilation Entry area were intact and functional. <br />Backfill & Grading <br />Reclaimed slopes at the East Portal Area and Access Road appeared stable, with no <br />evidence of slumping and no significant erosion. Reclaimed drainage channels appeared <br />stable, with perennial grasses and shrubs becoming established along the channels. <br />Processing Waste <br />Refuse Area RP-2/3/4 grading was contemporaneous with dumping. The pile appeared <br />stable with no evident depressions or gullies. Perimeter ditches appeared to be properly <br />maintained and functional. At Refuse Area RP-5A, two scrapers were spreading coal waste <br />from the approved temporary stockpile on the surface of the permanent disposal pile. The <br />pile appeared stable. Working surface appears to have a relatively uniform grade to the <br />north, with no evident depressions or gullies. Perimeter ditches appeared to be properly <br />maintained and functional. There was no appreciable dust generation from the scraper <br />activity. <br />Revegetation <br />Revegetated areas at the East Portal Ventilation Entry and Access Road, Refuse Area RP-1, <br />and the RP-5A subsoil pile were walked, and revegetated areas at various laydown areas <br />were observed from a distance. The growing season this year has been very dry, and <br />grasses on both reclaimed areas and native areas are dormant. <br />At the East Portal reclamation area, vegetation is relatively sparse, especially the eastern <br />half of the area. Perennial grass establishment is patchy, primarily crested wheatgrass, <br />Russian wildrye, and western wheatgrass. Shrubs including four-wing saltbush, <br />greasewood, and big sagebrush are widely scattered across the site, with small relatively <br />dense patches in a few locations. Due to the steep south facing slope and dry conditions <br />