INSPEC40618

• Permit No: C1981041
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 6/17/2003
• Media Type: D
• Archive: No

III. COMMENTS -COMPLIANCE
Below are comments on the inspection. The comments include discussion of observations made .
during the inspection. Comments also describe any enforcement actions taken during the inspection
and the facts or evidence supporting the enforcement action.
The Division verified compliance with cover soil replacement thickness in January 2003.
Numerous test holes were dug with a soil auger and sharpshooter shovel, and results are
documented in the DMG inspection report issued 1/31/03.
ii) Topsoil Conditioning and Seedbed Preparation
Permit required soil conditioning and seedbed preparation was limited to extensive
roughening of the soil surface, to provide microsites for seed catchment and seedling
establishment, moisture retention, and erosion control. On steep slope areas of all three
refuse disposal piles during 2002, the roughening was accomplished by extensively gouging
or pocking the soil surface with atrack-hoe bucket. The relatively level areas on the top of
the CRDA piles and the small area of 3:1 north facing slopes on the back side of CRDA-2
were roughened by contour ripping..Based on initial results, the practices employed appear
to have been very effective. Extensive soil roughening had not been required and was not
implemented on the lower CRDA pile benches that were reclaimed in 1994.
iii) Seeding During Proper Time-frame
Peak precipitation periods in the mine vicinity are spring (March -May) and late
summer/early fall (August-October). Approved seeding timeframes include dormant season
seeding (mid October through December), spring seeding (March/April), and summer seeding
(July/August). In 2002, CRDA-1 and most areas at CRDA-2 were permanent seeded in
April, immediately following seedbed preparation. RSRDA slopes and the reclaimed former
diversion ditch at CRDA-2 were permanent seeded in November, again immediately
following seedbed preparation roughening. 1994 permanent seeding was done during the
summer and fall. The spring and early summer of 2002 were extremely dry, and there was
no germination in the spring seeded areas until after a series of rains in late August and
September. Additional germination has occurred in those areas (particularly shrub species)
in the spring of 2003. Areas seeded in November 2002 have exhibited good germination
and initial growth this spring. Excellent establishment of seeded shrubs and grasses,
particularly greasewood, was noted on the RSRDA slopes.
iv) Proper Soil Stabilization Practices
As noted, 2002 reclaimed areas were extensively roughened immediately prior to seeding.
The permanent seedmix was applied by hydro-seeding, followed by application of 2 tons per
acre of certified noxious weed-free straw mulch with tackifier. On the RSRDA pile, soil
replacement was not completed until mid-summer, and because of the extremely dry soil
conditions and uncertain outlook for late summer precipitation, the decision was made to
delay seeding until the dormant seeding period. As approved in the permit, an interim
stabilization seeding of annual barley was applied following completion of topsoiling. The
barley crop provided some protective cover in late summer and early fall prior to initiation of
seedbed preparation,.and continues to provide some cover in addition to the mulch and
newly established perennial vegetation.