_INSPECTION - C1980005 ‎(35)‎

• Permit No: C1980005
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 8/13/2009
• 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.
The remedial treatment plan for the Wolf Creek Pre-law Area is presented in Attachment 13-16 of Volume 12A
of the permit application. In 2007, remedial grading was performed in portions of the Wolf Creek Pit area, and
portions of the area were also treated with aerial lime application and aerial seeding. Approximately 45.4 acres
of the Wolf Creek Pit spoils were subject to remedial treatment in 2007. In addition, the PL-1 channel was
seeded, and TRM liner was installed. The narrow dozer track disturbance was seeded at the same time.
During the inspection on 8/13/09, the Wolf Creek Spoils area that is still under bond was inspected by walking up
the PL-1 channel to the pond vicinity, up to the spoil ridgeline generally to the east of the pond, along the ridge to
the south, eventually circling back to the west of the pond, and down along the dozer track disturbance to the
west of the ridgeline, southwest of the pond. The following observations were made:
• There is lush growth of grasses this year on the slopes along Channel PL-1 and in other areas of the
Pre-law spoils that were not subject to remedial work in late 2007.
• The PL-1 channel appears stable, with generally good establishment of grasses and rabbitbrush along
the channel, and no rills or scour. Based on the vegetative growth, it appears that the channel does not
experience frequent or significant flow.
• A significant pool of water was ponded in the depression at the upper end of the PL-1 channel. The
level of the water was well below the elevation of the outlet to PL-1.
• Emergent vegetation growth including rushes along the pond margins and a stand of cattails at the south
end of the pond was noted. Roy Karo was not sure whether the pond had been sampled this year; the
Division recommends that sampling be conducted annually to establish water quality trend,
particularly with respect to pH, which was noted to be acidic(pH of 3.5) prior to the 2007
remediation project in the watershed.
• 2009 is the second growing season for the slopes that were graded, limed, and seeded in the fall of
2007. Treated slopes to the southeast of the pond (facing northwest)generally exhibit fair to good
establishment of seeded grasses, some seeded forbs, and rabbitbrush, while southwest facing slopes
to the northeast of the pond (generally north of the drainage due east of the pond)exhibit generally
poor establishment. Additional treatment to obtain better vegetative cover may be warranted on
areas of poor establishment, if conditions do not improve by next growing season. A possible
remedial method to consider on the relatively barren spoil areas would be to use temporary fencing to
hold a herd of cattle on the area of concern for a sufficient period of time, with the cattle to be fed by
distributing hay across the area. This method would incorporate seed and lime amendment, as well as
organic matter and nutrients.
• The slopes east of the ridge crest(southeast of the pond)are extremely steep(material was apparently
spoiled over this slope when the area was mined in the mid-1970's (pre-SMCRA). Upper portions of
the southeast facing slopes were graded and treated in 2007, with somewhat patchy vegetation
establishment to date. At the southeast nose of the ridge on the southeast facing slope within the
remedial treatment area, near the perimeter of the Wolf Creek spoil area, a spoil slump occurred in the
spring of 2008. This slope area was historically unstable prior to remedial grading. There is a scarp
reaching up to 10 or 12 feet in height running approximately 60 to 70 feet across the slope in this
location. Given the extreme slope gradients and original spoil placement techniques employed, the
Division does not believe it is likely that further efforts to eliminate the scarp would achieve long term
stability on the upper portion of the pre-law outslope. Based on the site conditions and spoiling
methods employed on the pre-law outslope,the Division will not require further remedial work
on the outslope.
• The small dozer track disturbance that was held out of the SL-2 bond release area is largely obscured
by vegetation, and appears to have been adequately reclaimed.
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