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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. Cover soil and topdressing for CRDA-1 will for the most part be excavated from the CBA-2 borrow azea, located immediately northwest of CRDA-l, on the opposite side of Coal Gulch. Contractor had installed a lazge diameter culvert in Coal Gulch to allow for access for construction of a temporary reclamation road onto CRDA-1 (for soil haulage). This proposed temporary roadis designated in the permit as Access Road #4. However, based on the Coal Gulch crossing location, it appears that the intended route onto the pile would follow roughly the same route used for the 1994 reclamation (reclaimed Access Road 9). A minor revision addressing the temporary road modification should be provided. Note that a 30" culvert will be required where the road crosses the Northwest Collection Ditch. Soil excavation from CBA-2 had not yet been initiated. Additional soil sampling to better define the extent of soils suitable for cover material andtopdressing is to be conducted in accordance with permit requirements. 2(21(02 1 met with Jim Stover and reclamation contractors on-site, to discuss various issues regazding final CRDA reclamation and Coal Canyon permanent diversion. Seedbed prepazation, seeding timeframes, and wildlife rock placement was discussed at the site and in follow-up phone conversations with Mr.Stover. "Extensive surface roughening" is specified for CRDA-2 south facing slopes (e.g. all broadcast seeded slopes at CRDA-2 except the north facing slopes that drain into the new upland diversion ditch). The extensive roughening will be accomplished by constructing shallow basins with [he track-hoe bucket, interspersed with small gouges created by the teeth on [he bucket. Basins should be spaced on approximate 4 Foot centers (or closer), and should be staggered and off-set, so as not to "line up" either across or up and down the slope. I requested that the operatornotify me when the contractor initiates the track-hoe roughening on the pile outslopes, so that I can observe the work in progress at an early stage. South facing cut slopes above (north of) the new upland diversion should also be extensively roughened with the track-hoe to the extent possible. Small azeas of non-rock slopes that cannot be accessed by equipment may need to be roughened by hand labor, to the extent safety allows, using sharpshooter shovel, picks, or similaz tools, prior to seeding. Backfill slopes associated with reclamation of the "old" upland diversion will also need to be extensively roughened. Broadcast seeded slopes that are not "extensively roughened" (such as CRDA-1 slopes and the north facing CRDA-2 upland diversion slopes) aze to be dozer tracked up and down slope prior to seeding. Permanent seeding should be accomplished as soon as practicable following seedbed preparation (especially important for broadcast seeding) and should be completed by mid-April (end of April at the absolute latest) for spring seeding as allowed by the permit (the eazlier in spring that seeding can be completed the better). If permanent seeding cannot be completed by late April, it should be delayed and applied as a summer seeding, between late June and mid-July ideally. The final permanent seeding window is dormant season seeding,.after October 15. If significant time elapses between topsoiling/seedbed prepazation and permanent seeding for broadcast seeded slopes, seedbed prepazation will likely need to be repeated prior to seeding. Prior to seeding of permanent reclamation azeas, boulders aze to be distributed in general accordance with the spacing criteria as outlined in the permit. Attempt should be made to use rocks in the size range