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S <br /> l , <br /> 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 /> Historic seep locations along terrace drains on eastern portions of CRDA-1 were moist at the surface, but not <br /> saturated. The underdrain outlet near the Pond 6 inlet location was also damp. <br /> Support Facilities <br /> The Division previously approved a technical revision application to allow use of the rail loadout(UTL) by another <br /> entity(Halliburton)for storage, loading and unloading of specified construction materials. Halliburton has <br /> completed some grading adjacent to the rail siding and set up a portable loader/conveyor, which has been <br /> operated periodically since November 2007. Halliburton had recently hauled a significant volume of construction <br /> soil to the site for future operational use; the material was stockpiled north of the rail switch location in the <br /> southern portion of the rail loop, as approved in a recent minor revision application. <br /> The North Portal (Cameo)substation and remaining powerline structure between the substation and the loadout <br /> will be reclaimed in conjunction with reclamation of the loadout facility, anticipated during 2008/2009, pending <br /> approval of PR-4, which is currently under review. Transformers were previously removed from the substation. <br /> The Substation "A"site was properly reclaimed and silt fenced in 2007. Vegetation cover is currently dominated <br /> by winter annuals. <br /> The Substation "B"site and associated bore hole location was reclaimed several years ago, and now supports a <br /> diverse stand of vegetation dominated by seeded perennials. <br /> The reclaimed South Fan site and access road supports a fair to good stand of seeded grasses and shrubs, <br /> though cattle grazing impacted grass establishment initially, prior to fence installation. The site is utilized heavily <br /> during the winter and spring by mule deer. <br /> At the North Decline reclaimed area, a cheatgrass control program utilizing herbicide application and <br /> interseeding was implemented in 2006/2007. To date, the control efforts do not appear to have been successful. <br /> There was essentially no emergence of seeded species in 2007, and the cover of cheatgrass and associated <br /> winter annuals appears to be significantly higher now than was the case last spring. <br /> At the RSRDA soil borrow area, seeded vegetation cover has slowly but steadily increased since the seeding in <br /> 2002. Winter annuals are still a significant component of the stand, but perennial grasses and forbs are <br /> represented at higher densities than in the immediately surrounding undisturbed areas. The electric fencing <br /> around the seeded area is down, and will need to be repaired and functional prior to turnout of cattle in <br /> adjacent areas. <br /> At the 2-West Portals, the portal sites themselves support very little vegetative cover(apparently due to a <br /> combination of soil conditions and steep slopes), while adjacent stockpile and substation reclaimed areas exhibit <br /> good perennial establishment. <br /> Revegetation/Reclamation Success <br /> Revegetation success was not closely evaluated, due to season (cool season perennials have only very <br /> recently initiated growth). Success has been variable; the best success over a relatively large area is at <br /> CRDA-1, where a diverse stand of cool and warm season grasses, forbs, and various shrubs has been <br /> established, with minimal presence of winter annuals or other weedy species. Most other large reclaimed <br /> areas exhibit a relative lack of one or more desirable components, and heavy abundance of cheatgrass and <br /> associated winter annuals (annual wheatgrass, annual barley, storksbill, etc.) is a widespread problem. <br /> Cover has been sufficient in the various reclaimed areas to prevent excessive erosion. <br /> During the inspection on March 19, the seeding contractor, WD Yards, was on site applying hydro-seed <br /> and hydro-mulch to the extensively roughened outslopes of Access Road 1 A, and to a small area in the <br /> vicinity of Pond 8. The seed and mulch was properly applied in two separate operations; seed first, <br /> 6 <br />