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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 />to be taken in future grading to ensure that gouges are consistently oriented perpendicular to slope, to <br />provide for maximum water retention, erosion control, and micro-site functionality. <br />Processino Waste <br />Most areas of both CRDA waste disposal sites and the RSRDA waste disposal site were walked. There were no <br />indications of instability or excessive erosion. Diversions, perimeter ditches, and terrace drains appeared to be <br />properly maintained and functional. <br />Some steel beams and walkway structure from demolition of the office facility had been temporarily stored on <br />top of the RSRDA. Supplemental documentation (depth measurement and photo) was included in the 2ntl <br />Quarter Waste Pile Certification report, to confirm adequate cover thickness of non-toxic cover (gravel) on top of <br />the RSRDA, as previously requested. <br />There had been no recent disposal of coal waste on the open portion of CRDA-1, but with recent initiation of <br />reclamation at the South Portals and anticipated reclamation of the unit train loadout area, it is expected that <br />there will be additional disposal at the site in the near future. <br />Suooort Facilities <br />The Division previously approved a technical revision application to allow use of the rail loadout by another entity <br />(Halliburton) for storage, loading and unloading of specified materials. Storage and handling of materials has <br />not yet been initiated, but site preparation and grading work has begun, and fill dirt for site grading was being <br />hauled to the site during the inspection. <br />Final reclamation had recently been initiated at the South Portals area. Demolition of the office facility structure <br />on the portal bench had been completed, and French drain construction was in progress at the South Portals <br />during the inspection. There was a pile of concrete rubble, and miscellaneous small demolition debris remaining <br />in the area of the demolished office structure on the upper bench. This rubble will be mixed with fill dirt and <br />compacted at the base of the highwall backfill. Fill dirt will be used to backfill the two entries from the portal <br />openings to the concrete seals, upon completion of French Drain installation. A 9 foot high concrete wall, which <br />had formed the back wall of the office structure along the northeast side of the portal bench, had been left intact. <br />The operator felt, and I agreed, that it would be prudent to leave the wall intact, as the segment that will extend <br />out from the highwall backfill would effectively serve as a safety barrier, to catch small rock that might <br />occasionally fall from the steep slope above. Excavation and demolition of remnant concrete foundations in the <br />wash plant area (lower level of the South Portal facilities) was evident, and some material had been pushed into <br />Pond 8 (which will be partially backfilled to result in a smaller pond upon completion of the South Portals <br />reclamation project). <br />The North Portal (Cameo) substation and remaining powerline structure between the substation and the loadout <br />will be reclaimed in conjunction with reclamation of the loadout facility, anticipated during 2008/2009, pending <br />approval of PR-4, which is currently under review. Transformers were previously removed from the substation. <br />Reveaetation/Reclamation Success <br />South Portal Vicinity <br />The regraded light use road above the RSRDA borrow area was seeded and mulched in August. Seeded <br />species have not yet germinated. Operator planned to seed and mulch the <br />5 <br />