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COMMENTS -COMPLIANCE ~~,.,~ SI/'n~P/~,r~Q (.~v-0~' <br />~~~/s a~~n~~oi ~~ <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments also describe any enforcement actions taken during <br />the inspection and the facts or evidence supporting the enforcement action. <br />Phase II Bond Release for the 720 Pit (cont.) <br />Vegetative Cover (cont.) -The Operator did use the reclaimed area for grazing in the <br />summer of 2000. They had 400 head of cattle grazing for two weeks. This is equivalent to a <br />50% utilization rate. They indicated that they would use the reclaimed area for grazing again <br />this summer (2001) at about the same rate. An excellent stand of Big Sagebrush has been <br />established, with seed heads were observed on several of the shrubs. Some of the other <br />dominant species observed were Yarrow and Fringed Sagebrush. The weed control <br />measures that have been undertaken the last couple of years have proven to be very <br />successful. Some Canadian Thistle was observed but to a much lesser extent than in the <br />past several years. The Operator should continue weed control as necessary. <br />Topsoil Replacement -The permit requires that a minimum of six inches of topsoil be <br />replaced on the reclaimed 720 Pit. The Operator did not provide any data on topsoil <br />replacement in the Bond Release Application so the Division took several field <br />measurements. A total of six holes were dug to measure the topsoil replacement depth. <br />The depths ranged from seven inches to eleven inches with an average depth of 9.7 inches. <br />The first two of these holes were about 500 feet West of Pond A with depths of 10 and 11.5 <br />inches; the second two holes were about 1000 feet North (of the first two holes), both having <br />depths of 11 inches; the third two holes were about 300 feet North of Ditch PD2 and 250 feet <br />East of the edge of the highwall with depths of seven inches and 7.5 inches. The field <br />measurements of the topsoil replacement depths confirmed that the topsoil was replaced in <br />accordance with the permit requirements. <br />Hydrologic Reclamation (Sedimentation) -The Operator used sedimentation modeling to <br />further demonstrate Phase II Bond Release criteria (Rule 3.03.1(3)(b)) have been met using <br />the Revised Universal Soil Loss Equation (RULSE). These calculations were confirmed by <br />the Division. The calculated (estimated) sediment yield for the reclaimed 720 Pit was 0.54 <br />Tons/Acre/Year. The calculated (estimated) premining sediment yield was 1.12 <br />Tons/Acre/Year. This gives an estimated postmining sedimentation yield of 48% of the <br />premining yield. The criterion for sedimentation for this area has been met. The inspection <br />confirmed the calculations. There was no noticeable erosion on the reclaimed 720 Pit and <br />both of the ditches (PD1 and PD2) did not appear to contain any sediment. Both ditches <br />appeared to be stable and were well vegetated. There did not appear to be any sediment <br />being deposited at the inlet of Pond A. There did appear to be a small low spot (where water <br />was pooled) in Ditch PD1 about 500 feet before it converges with Ditch PD2. This did not <br />appear to be significant and did not appear to be causing any problems. <br />Phase II Bond Release for Pit 1 <br />The Operator is requesting a 25% ($217,298.00) Phase II Bond Release for Pit 1. The total <br />cost for reclamation of Pit 1 was $869,195.00. <br />