Laserfiche WebLink
-7- <br />3. The effect of mulch on the site with respect to decreased erosion <br />potential appears to be over estimated. Field inspection of the site <br />indicates that little mulch remains on site. Therefore, the use of <br />an anchored mulch value is questionable. In addition, site <br />conditions appear to exceed the limits for which mulch at the rate <br />specified is considered effective by the mulch factor table used in <br />calculating MUSLE. <br />In addition to these problems with the factors in the equation, field <br />inspections by the Division have encountered substantial gullying problems on <br />the site. The amount of erosion is in excess of that observed by the Division <br />on undisturbed areas adjacent to the site. This is further indication that <br />the equation, as applied, is not representative of field conditions. <br />The Division finds, based on field inspections and insufficient demonstration <br />by the operator, that the pit area does not meet the criteria of Rule. <br />3.03.1(3)(b). The Division also rejects the operators position that due to a <br />change in land use, additional sedimentation should be expected from the <br />reclaimed area. A change in land use was not submitted by Sun Coal Company <br />for this site. <br />Slash Piles - The landowner has complained that an area between the <br />sediment pon s and the access road west of the reclaimed area contains slash <br />piles which preclude the approved PMLU on this area. He states that this pile <br />is dangerous to his cattle and decreases the area available for grazing. The <br />operator contends that the piles are small, and provide good wildlife <br />habitat. During field inspections it has been noted that other slash piles <br />exist on the landowner's property which are not affiliated with Sun Coal. The <br />Division finds that the slash piles do not interfere with the approved PMLU, <br />which is grazing and wildlife habitat. <br />Based on these specific findings the Division has issued a proposed decision <br />to approve in part, the bond release request for the Meadows No. 1 Mine. This <br />proposed decision is contained in the "Proposed Decision" section of this <br />report. The Mined Land Reclamation Board affirmed the Division's findings and <br />approved the decision as final, as discussed above, on May 22, 1986. <br />