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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 /> General Comments <br /> This was a partial inspection of portions of the mine site, conducted by Dan Mathews of the DRMS Grand <br /> Junction Field Office. There was no operator contact present. Areas inspected included the North Portal Area, <br /> disturbed areas along Coal Creek, and the South Portal Area and RSRDA waste disposal area. <br /> The South Portal reclamation project has been largely completed. The seeding contractor(WD Yards)was on- <br /> site on 3/19, hydro-seeding and hydro-mulching the Access Road 1A fill slopes and Sediment Pond 8 areas. <br /> Weather during the inspection was clear and warm. There had been precipitation at the site last week, but <br /> surface soils were dry at the time of the inspection, as were the sediment ponds that were observed. <br /> Roads <br /> New Access Road 1A appeared to be in good condition, including travel surface, drainage ditches and culverts. <br /> The slopes above and below the road, which were roughened and seeded earlier this year appeared to be <br /> stable, with no slumps, rills, or gullies. Seeded vegetation has recently germinated on the seeded areas. It is <br /> too early in the growing season to assess success of the seeding. Seedling densities and diversity are variable, <br /> with the best growth at present near the south end of the reclaimed road slopes. Seedling density appears to be <br /> lowest and least diverse(mostly sparse greasewood at present)along the northern portion of the road outslope. <br /> Soils in this area appear to exhibit possible effects of high sodium content(surface film from dispersive effect), <br /> which may limit plant establishment. <br /> Hydrologic Balance <br /> Drainage and sediment control structures appeared to be properly maintained and functional in the areas <br /> observed, including North Portal Area, South Portals, and Coal Creek corridor area. Sediment Ponds 8, 9, 6, 10, <br /> 11, and 13, and the CBA-1 sump were all dry. Perimeter berms and the SAE silt fence at the North Portal area <br /> were in good condition. <br /> There was no evidence of leakage in the vicinity of the recently plugged and backfilled 001 discharge pipe in the <br /> backfilled South Portals area. There was a trickle of flow out of the culvert below Access Road 1A, originating <br /> from the buried French Drain. <br /> Backfilling and Grading <br /> The various backfilled and graded areas were walked, and in general slopes appeared to be stable, with no <br /> excessive erosion, slumping, or other indications of instability. <br /> Backfilled slopes associated with the South Portals reclamation project appeared stable, with no indication of <br /> slumps or erosion. <br /> Processing Waste <br /> The RSRDA waste disposal site was walked, and no problems were noted. There were no indications of <br /> instability or excessive erosion. Diversions, perimeter ditches, and terrace drains appeared to be properly <br /> maintained and functional. <br /> Revegetation/Reclamation Success <br /> Backfill slopes and road slopes in the South Portal area were seeded in February and March, and seedling <br /> vegetation has recently emerged. The backfilled highwall looks very promising, with high density of <br /> various seeded shrubs and grasses. Seedling density and diversity on slopes associated with new Access <br /> 3 <br />