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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 />A Bond Release Inspection for SL -02 was conducted at the Hamilton Mine on Thursday, 3 -Jun- <br />2010 beginning at 9:30 a.m. Marcia Talvitie and Dan Mathews represented the DRMS. Other <br />participants included Johnny Rich ( Honeywood Coal Company), Jim Stover, P.E. (consultant to <br />Honeywood) and Dave Andrews (Landowner). Weather conditions were clear, warm and <br />breezy. <br />With the SL -02 application, Honeywood Coal Company (HCC) seeks Phase Il bond release for <br />86.8 acres. The original application package was received by the Division on 30- Oct -2009. <br />Supplemental information was provided on 16- Dec -2009, and the application was determined <br />to be Complete on 18- Dec -2009. The Division reviewed the application for adequacy, and <br />issued a Preliminary Adequacy Review on 27- May -2010. <br />Active mining took place at the Hamilton Mine in 1992 and 1993. Topsoil redistribution occurred <br />in 1992 and 1993, and seeding of all reclaimed areas with the approved Rangeland seed mix <br />was completed in 1993. Phase I bond release for the entire permit area, exclusive of ponds and <br />ditches, was granted with SL -01 in August 1994. In 1995, the entire reclaimed area was reseeded <br />using the some seed mix. Re- seeding with grasses only was accomplished on 80 acres in 1998. <br />The inspection began with a review of the mine maps, reclamation history, and the vegetation <br />sampling plan. The sampling, conducted in 2009, incorporated the reclamation in Mining Area <br />No. 1; undisturbed area west of Mining Area No. 1; and the sagebrush and grassland reference <br />areas. With SL -02, Phase 11 Bond release is also being requested for Mining Area No. 3 and two <br />topsoil stockpile areas located south of the haul road that leads to Mining Area No. 3. These <br />areas were not included in the 2009 vegetation study. <br />Mining Area No. 1 <br />Depths of topsoil replacement for Mining Area No. 1 have not been previously reported by HCC. <br />Topsoil depths were measured at twelve locations during the inspection. Values ranged from 5" <br />to 13 ", with an average of 9.1". The permit currently requires a 10" replacement thickness. <br />Based on the soil thickness data collected, the Division's preliminary determination is that an <br />adequate soil thickness was not replaced, within Mining Area No, 1. <br />This reclaimed area encompasses 73.1 acres, and lies west of the natural drainage that bisects <br />the permit area. Our inspection commenced at the southwest corner of the fenced area, and <br />meandered throughout the parcel in a generally counter - clockwise direction. Vegetation <br />success is highly variable across Mining Area No. 1, with distinct zones apparent. The southern <br />and western portions exhibit good establishment of seeded species, including both warm and <br />cool season grasses, shrubs and sub - shrubs. Warm season grasses included blue grama, sand <br />dropseed, and galleta; cool season grasses included needle- and - thread grass, indian rice grass, <br />and bottlebrush squirreltail. Four -wing saltbush is the dominant shrub and exhibits relatively high <br />densities; the sub -shrub winterfat is present, though not abundant. The forb scarlet globemallow <br />is relatively abundant. Seedlings of four -wing saltbush and winterfat were observed in some <br />locations. The weedy annual cheatgrass was present at relatively low levels, and a few small <br />Hamilton Mine C- 1991 -078 3- Jun -2010 <br />-1- <br />