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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 />entire CRDA-2 disposal area, all of CRDA-1 except the temporary road segment extending <br />up onto the pile from Haul Road 5, and the slopes of the RSRDA disposal area, as a <br />component of the Phase 1 Bond Release (SL-2) in 2003. <br />Suooort Facilities <br />All of the various mirie facility areas were inspected. Reclamation including facilities <br />removal, backfilling and grading, topsoiling, and initial revegetation has been completed at <br />most facility areas, with the South Portal Area, top of the RSRDA refuse area, and the Unit <br />Train Loadout (UTL) being the major exceptions. The UTL is in temporary cessation and <br />may be re-activated to allow loading of coal from other mines in the area in the future. <br />South Portal reclamation and top of RSRDA reclamation is scheduled to be initiated during <br />the fourth quarter of 2004 and completed by the end of 2005. A temporary road on the <br />CRDA-t refuse disposal area has been left open to allow for further disposal of coal waste <br />generated by clean-up of remaining facility areas during final reclamation. Future <br />reclamation work will also include removal of sediment ponds and associated temporary <br />drainage structures, and final drainage channel construction on Coal Gulch within the CBA- <br />2 borrow area, Coal Creek in the vicinity of Ponds 6 and 10, and several ephemeral <br />drainages through the North Portal reclamation area. <br />All mine portals and shafts have been sealed and backfilled with the exception of the two <br />portals at the South Mine. The South Mine workings have been blocked off approximately <br />100 feet inby the portals by concrete seals, and the portal openings are temporarily <br />secured by metal gates and paneling. The temporary measures were secure at the time of <br />the inspection. There was seepage from the portals vicinity as normally is the case. The <br />seepage flow of for 2 gpm is intercepted by a drain on the upper bench parking lot and <br />conveyed via pipe to Sediment Pond 8. <br />To soil <br />Topsoil/cover soil has been replaced to required thickness on the CRDA-1, CRDA-2, and <br />RSRDA parcels reclaimed in 2002, and adequate cover soil thickness was verified as a <br />component of the Phase 1 Bond Release (SL-21. Sampling indicated considerable variability <br />in surface soil quality on the refuse sites. Areas with elevated sodicity/salinity were <br />identified on CRDA-t and CRDA-2, however initial vegetation establishment on the <br />reclaimed waste disposal sites appears to be promising, with a significant density of seeded <br />grasses and shrubs present on most areas. <br />Topsoil from stockpiles has also been replaced on other sites reclaimed in recent years, <br />including the North Portal, conveyor corridor, 2 West Portals, South Fan, CBA-1, CBA-2, <br />and RSRDA soil borrow areas, and reclaimed areas along Coal Creek in the vicinity of Pond <br />10. Sampling and/or poor vegetation establishment has indicated apparent soil quality <br />problems on the backfilled 2-West portal slopes and a portion of the North Portal <br />reclamation area. Mitigative treatments may be warranted in these areas. <br />3 <br />