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Ill. COMMENTS - COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made during <br /> the inspection. Comments also describe any enforcement actions taken during the inspection and the <br /> facts or evidence supporting the enforcement action. <br /> Support Facilities: Halandras Landfill was inspected. No liquids are disposed of at these pits. Scott <br /> estimated the water table was in excess of 150 ft below the landfill area. BME uses this area for disposal <br /> of non-coal waste; fiberglass ventilation tubing, wood, tires, and other operational debris. Hydrocarbon <br /> fluids (oils, etc.) are hauled off site by a contractor <br /> Degas vent pads; LWB10-4, LW11-1 Nitrogen wells; N8-51, N8-55, N9-56, SC-HG44-1, SC-HG44-2, <br /> RS4, RS5, were observed. There was no evidence of discharge off these pads. Active sites are identified <br /> with their borehole name with a sign. After reclamation of the borehole, a cemented plug remains in <br /> place with an aluminum cap stamped with the borehole identification number. Reclaimed boreholes <br /> visited were LW10-2, SC-SLI, SC-SL3 and SC-HG-59. SC-HG-59 and SC-SL1 were reclaimed in Fall <br /> 2009. These sites have been graded & seeded. The soil surface was left rough. Some emergence of <br /> perennial species was seen, but primarily annual species were observed. Site SC-SL3was seeded in <br /> 2007. The vegetation at this pad has established well. A black hose remains were the borehole was. A <br /> permanent marker needs to be installed at this location marking the sealed borehole. The operator <br /> estimated that RS4 would be closed in another week or two from this inspection date. <br /> Wildlife: A pair of Osprey is nesting near the Raw Water Lagoon. One bird was observed on the nest <br /> during the inspection. The operator stated that the birds remained in the area during the vault and <br /> waterline construction project. A flock of White pelicans were also observed near the lagoon area. The <br /> operator reported that Colorado Division of Wildlife and the BLM have identified Townsend's big eared <br /> bat in the Staley-Gordon mine adjacent to the sealed East Portal. These other agencies continue to <br /> monitor these bats. <br /> Reclamation Success: Several reclaimed areas were inspected; East Portal and RDH-1. Both were <br /> reclaimed and seeded in 2002. The East Portal area has a south facing aspect and limited soils. This <br /> area had been disturbed previous to the east portal construction. The backfilled slopes are steep and the <br /> surrounding undisturbed terrain is very rocky. The vegetation has established well considering the steep <br /> and dry locale. Although Cheatgrass continues to be present, desirable perennial species have become <br /> well established as well. No erosional gullies or sediment transport could be noted in this area. The <br /> reclaimed area appears stable with no signs of noxious weed establishment. No surface settleing or <br /> surface cracking was observed over the portal face. <br /> RDH-1 was also reclaimed in 2002. Soils and aspect are very different. The resulting vegetation at this <br /> location has established a good and diverse stand of perennial grasses and woody shrubs. The operator <br /> has left the soil surface very rough. The operator has found that thinner soils replaced favors the <br /> establishment of perennial seeded species over invasive annual species (Cheatgrass). <br /> 4 of 6 WHITE- File YELLOW-Operator PINK-Specialist <br />