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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 />contain and convey flood water and debris away from the pile, with minimal need for future <br />maintenance. <br />In essence, the construction process resulted in an extremely over-sized diversion structure <br />formed by the north facing slopes off the top of the refuse pile and the south facing <br />cutslopes on the steep canyon sides, with the rip rapped ditch channel at the bottom. Both <br />the north facing and south facing disturbed slopes drain into the ditch channel, and runoff <br />from these slopes is not routed through sediment treatment structures. This fact was <br />specifically addressed within the permitting process for the north facing refuse slopes, and a <br />small area exemption was granted based on calculated extremely low peak flow velocities <br />and minimal sediment generation. Supporting documentation is presented in permit Tab 13, <br />Appendix 13-2, pages CRDA2-12a and CRDA2-13n through 13s "Untreated Drainage into <br />Upper Diversion Ditch". The refuse slopes were adequately roughened and mulched <br />immediately after topsoil placement, and an excellent grass dominated vegetation cover has <br />become established, with no evidence of erosion or sediment deposition. <br />Sediment control for the south facing cut slopes was not specifically addressed, although <br />the slopes were roughened to the extent possible with atrack-hoe, hydro-seeded and hydro- <br />mulched. In the Division's judgement, the steep south facing cut slopes are in essence a <br />component of the upper diversion, given that the desired channel alignment and elevation <br />(lower than the top of the refuse pile} could not have been achieved without excavation that <br />resulted in the cut slopes. As such, no specific sediment controls are warranted or required <br />by regulation, and evidence of excessive erosion or sediment deposition from the slopes has <br />not been observed. At the conclusion of the inspection, the OSM representatives indicated <br />that their preliminary judgement was in concurrence with DMG, although further permit <br />review might be warranted. No other potential offsite impacts were noted during the <br />inspection. <br />b. Reclamation Success <br />Reclamation success evaluation for the purposes of the special focus inspection, involves <br />assessing the extent to which approved methods for coal mine waste bank reclamation <br />have been, or are being, conducted. <br />Specific items listed in the oversight topic outline include verification of: <br />i) proper placement of cover material and topsoil; <br />ii) proper topsoil conditioning and seedbed preparation; <br />iii) seeding during proper timeframe; <br />iv) proper soil stabilization practices; <br />v) acceptable development of seeded vegetation <br />The lower three benches of CRDA-1 and CRDA-2 were reclaimed in the fall of 1994, and <br />apparent reclamation success was evaluated in a 1997 special focus inspection (see <br />3 <br />