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III. 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 />This was a partial inspection of the Carbon Junction Mine conducted by Tom Kaldenbach of DMG. Darcy <br />Ferguson, one of the operator's consultants, went along on the inspection of the North Pit. Marcia Talvitie <br />of Four Corners Materials was also along on the inspection of the North Pit. <br />The Division recently issued a proposed decision to approve bond release application SL-2 for Phase I, <br />II, and [II release of the coal reclamation bond for the South Pit azea and other areas that are part of the <br />Ewing Mesa gravel pit permit. The approved post-mining land use of the SL-2 area is industrial <br />(gravel pit). The proposed decision is in the public comment period. <br />The ground was dry. No problems were found on the site. <br />Backfilling and Gradin¢ <br />No backfilling has been done in the North pit since 2003. During the inspection, the operator's <br />consultant described a new backfilling and grading plan for the North Pit that the operator is <br />considering for submittal as a revision to the permit. <br />Currently-approved backfilling plan jor North Pit -The currently approved plan is for the North Pit <br />to be backfilled with spoil material (Photo 1). The spoil would have two sources: the spoil that was <br />downcast on the slope immediately below the pit and the spoil that is in the permanently reclaimed <br />spoil azea approximately one-half mile from the pit. <br />Backfilling plan for North Pit that is under consideration -The new backfilling plan that is being <br />considered for submittal would involve blasting the upper part of the highwall and the ground <br />immediately upslope from the top of the highwall (Photo 2). The resulting summit of the hill would be <br />approximately 30 feet less than its cun•ent elevation. The operator's consultant explained that the chief <br />motivations for this new plan aze that the plan would provide greater slope stability by making it easier <br />to achieve a 3:1 slope and it would avoid redisturbing the downcast spoil slope downhill from the pit. <br />The plan may further support the approved postmining residential land use by creating more <br />developable land area. <br />