_INSPECTION - C1980005 ‎(34)‎

• Permit No: C1980005
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 7/15/2008
• Email Name: DTM
• Media Type: D
• Archive: No

III. COMMENTS - COMPLIANCE
Below are comments on the inspection. The comments include discussion of observations made
during the inspection. Comments also describe any enforcement actions taken during the inspection
and the facts or evidence supporting the enforcement action.
Inspection Considerations Specific To Phase II Bond Release
(1)Topsoil replacement in compliance with approved plan—
Within the SL-3 bond release area, all available topsoil was replaced on reclaimed areas prior to 2003. Soil
replacement depth sampling has been conducted and reported annually by SCC over the course of the permit
life, and verification sampling has also been periodically conducted by the Division. From 1980 to 1996 (e.g.
roughly corresponding to BRB-2 and BRB-3), approved average replacement thickness was 12"to 15". From
1997 through 2003 (BRB-4), approved replacement thickness ranged from 3"to 10", averaging approximately 6".
Summary documentation was provided by SCC in Attachment D of the SL-3 application, presenting the results
of 933 sample holes over the entire bond release area (slightly less than one hole per 2 acres). With the
exception of a few outliers, soil thickness ranged from 6"to 30", with an average thickness bf 15.6".
Due to the extensive soil depth sampling previously conducted and reported, the Division did not undertake
additional soil depth checks during the inspection. There were no areas observed where topsoil had obviously
not been replaced, nor were there areas where soil or vegetative conditions were indicative of deleterious
materials in the root zone (with the exception of a few very small and isolated locations affected by saline seeps,
primarily in the vicinity of reclaimed highwalls).
(2)Vegetative cover and "bare areas" assessment—
Documentation presented in the bond release application indicates that the approved reference area cover
standard was achieved within each of the three bond release blocks included in the SL-3 release request area.
Observations made during the inspection support the sampling results reported. There were no significant bare
areas or areas where cover was obviously insufficient and contributing to excessive erosion. Almost all of the
erosional areas observed appeared to be remnant from an earlier stage of reclamation, or a consequence of
concentrated flow from an obvious source, such as an existing or former road or ditch.
(3) Species composition/diversity visual evaluation---
There is a relatively high degree of vegetative diversity among vegetated parcels, reflecting differing topography,
soil conditions, reclamation practices, climatic conditions and other factors. The older revegetated stands within
BRB-2 generally exhibit somewhat higher cover and production, with a higher component of alfalfa and
introduced grasses, while the most recent seedings within BRB-4 reflect lower cover and productivity, with a
higher component of native species and somewhat higher over-all diversity. Parcels within BRB-3 seemed on
average to be somewhat more productive than BRB-4 areas, and somewhat more diverse than BRB-2 areas.
Shrub planting areas appear to have been fairly successful in a few drainage area plantings (notably in BRB-4
Parcel 98-1 a, along PM-6 above Stock Pond T-32), but in a majority of the shrub planting sites observed, low
numbers of stunted shrubs.remained. However, significant expanses of shrub stands, primarily big sagebrush
or big sagebrush/snowberry, have developed in various locations throughout the bond release blocks, likely from
native seedbank in the respread topsoil. BRB-2 sagebrush stands are evident in Photos 3942, 3943, 3962,
3964, and 3985. A dense big sagebrush/snowberry community within BRB-3 along PM-10 is shown in Photos
3998 through 3990, and a diverse sagebrush grassland site is shown in BRB-3, PM-18 watershed, in Photo
3983. A highly diverse stand of native grasses, forbs, and shrubs was observed across the upper portions of
parcel 98-1 a, in the BRB-4, PM-6 watershed, depicted in Photo 3977. The stand included at least 8 grass
species, 10 forb species, and 6 shrub species in the immediate vicinity of the photo point.
Small parcels of undisturbed native shrub habitat that were retained within some of the large reclamation blocks
have contributed to over-all diversity of the landscape and are important habitat features for mule deer and other
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