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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 />The 1994 reclaimed areas were straw mulched following seeding. Some gully repair work <br />was required in the early years after seeding, but vegetation cover combined with the slope <br />terrace drains has effectively controlled erosion, with minimal repair work necessary in <br />recent years. <br />v) Acceptable Development of Seeded Vegetation <br />Promising stands of seeded vegetation are becoming established in most areas seeded in <br />2002, although there are also scattered areas on the CRDA piles where seeded vegetation <br />is sparse. In some cases, the spotty establishment (particularly on CRDA-11 may be due <br />to elevated salt concentrations Isee above discussionl. There are also a few small areas <br />where the vegetative cover is dominated by a weedy annual crested wheatgrass. In <br />general, vegetation on the 2002 seeded areas meets or exceeds typical expectations for <br />initial establishment in asemi-desert environment, although it is still too early to make <br />conclusions regarding seeding success or failure. <br />Vegetative cover on older revegetated areas (seeded in 1994) appears to be sufficient to <br />stabilize the soil surface and prevent excessive erosion. Most portions of the predominantly <br />north facing slopes of CRDA-1 support an effective perennial cover, with a relatively diverse <br />assemblage of seeded grasses and shrubs, with a minor component of perennial (orbs. The <br />1994 reclamation on the predominantly souih facing slopes of CRDA-2 appears to be <br />effective in controlling erosion, but significant areas are heavily dominated by fourwing <br />saltbush, with a scattering of other shrub species and minimal perennial understory. In <br />response to this concern, the operator interseeded the slopes in the fall of 2001 with <br />various shrubs (other than four-wing) and grasses. To date, there does not appear to have <br />been a significant response from the interseeding. 'If improvement is not apparent by next <br />growing season, consideration of more extensive remedial treatments may be warranted. <br />This concludes the Division's assessment, pertinent to the Coal Mine Waste Bank Special <br />Focus Inspection for the processing waste disposal areas at Roadside Mine. <br />Availability of Records <br />Records were checked at the offices of J.E. Stover & Associates on the afternoon of June <br />17. Records were on file and up-to date through the 1s` Qtr., 2003 (see atttached records <br />check form). As noted, between the first quarter of 2002 and June 2003, no compaction <br />testing was required on any of the waste disposal areas, because there was not active <br />placement and compaction of waste material during that time period. Placement of coaly <br />material from along the conveyor corridor was initiated along the temporary "in pit" road on <br />CRDA-1 the week of June 16. Compaction testing and compliance documentation will be <br />necessary. <br />6 <br />