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-~- <br />2. Calculations by the Division indicate that rainfall and runoff <br />factor (R) were underestimated by the operator. This appears to be <br />due to omitting the snowmelt runoff factor. <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 <br />site indicates that little mulch remains on site. Therefore, the <br />use of 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 />III. Criteria for Schedule for Release of Performance Bonds - Haul Road. <br />In July, 1984 a technical revision was approved with conditions fora haul <br />road decommissioning plan. The Division finds that due to the nature of the <br />designed structure, that the three phase bond release approach does not <br />apply. In this specific case, bond may be released pursuant to <br />Rule 3.03.1(3)(d) when it has been determined that the decommission plan has <br />been successfully implemented and the road is functioning as designed, in <br />accordance with the approved post mining land use. Outslopes and other <br />vegetated areas must meet the criteria of Rule 4.15.10(2), which apply to <br />residential and industrial post mining land uses. This Rule states that "the <br />ground cover of living plants shall not be less than required to control <br />erosion." <br />Im lementation of the Decommission Plan - The Division has received <br />certification from t e operator t at t e roa has been decommissioned as per <br />the approved plan. However, although constructed as designed, there is <br />evidence that the decommissioned road is not meeting the requirements of <br />Rules 4.03.2(1)(b), 4.03.2(1)(d), 4.03.2(1)(f)(i), 4.03.2(3)(c)(i), <br />4.03.2(3)(d)(viii), and 4.03.2(4)(a)(iv). Rule 4.03.2(f)(i) requires that <br />retention of the road in the post-mining land use is contingent on the road <br />meeting all applicable performance standards. The remaining rules which are <br />cited set forth these standards. <br />