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III. COMMENTS-COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made outing the inspection. Comments also <br /> describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. <br /> This was a partial inspection conducted by Janet Binns of CDRMS. The mine no longer extracts coal,but the remaining <br /> surface pit(Pit B) is permitted to dispose of flyash. CEC caps,regrades,topsoils,mulches and seeds the pit as the ash till <br /> progresses. The weather was windy and cold. The mine site was dry. The purpose of the inspection was to observe auras <br /> that have exhibited Cheatgrass invasion and discuss methods of control employed by the operator. Present at the inspection <br /> were: Don MacDonald and Danny Kipp of Coors Energy Company, Mike Savage of Savage&Savage Environmental, <br /> consultants for CEC,George Beck Colorado State University, Sandy Brown,Tony Waldron and Janet Binns of DRMS. <br /> Roads: CEC has begun to plane off road base material from the haul road return from the pit to the facilities. This will <br /> lower the height of the road corridor to blend in with the surrounding reclaimed parcels. CEC does not rely on this travel <br /> corridor from hauling ash or spoil to the B-pit as the active area in the B pit progresses northward. <br /> Revegetation and Reclamation Success: Although the Keenesburg Mine does not have problem with Cheatgrass(aka <br /> Downy Brome,Bromus tectorron)infestation,there are localized reclamation areas at the mine site that have pervasive <br /> Cheatgrass presence. George Beck is an expert in weed science at CSU. At the request of DRMS, Mr. Beck is preparing a <br /> brochure to aid operators in effectively manage Cheatgrass invasion. The Keenesburg Mine was chosen for observation <br /> since CEC has recognized Cheatgrass invasion, and has made efforts to control the Cheatgrass. Parcel 9 at the southern end <br /> of the permit area was observed. On the strips that the B horizon soil was used as the topdressing,vegetation is denser and a <br /> lower concentration of Cheatgrass was observed,than on the strips that received the A horizon(sugar sand)as the <br /> topdressing. Photos below.Cheatgrass is also noted at the base of sand sage and established perennial bunch grasses. On <br /> reclamation stands with thinner cover,Cheatgrass was noted becoming established on the bare soils. Other reclamation <br /> parcels that were noted were Area 10, 16 and 25. CEC has used fire as a control method,timing the burning to after <br /> antithesis but prior to seed maturity. Timing of this method was critical to reducing seed source. Discing and reseeding in <br /> Area 25 was another method of control. <br /> Overall the vegetation on the urine site was in good condition. The presence of Cheatgrass on the site is not considered an <br /> infestation but was observed to assess the concerns operators in Eastern Colorado have with Cheatgrass and to observe the <br /> response from different management techniques. <br /> No maintenance problems were noted during this inspection. <br /> j4R�'RE - <br /> Reclamation parcel Cheatgrass germinating&emerging at base of perennial species <br /> Page—3—of—5—Pages,(date) 1713'20eg(initials) Tb <br />