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III. GOMMENTS -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 />This was a partial minesite inspection conducted on the afternoon of May 24 and the <br />morning of May 25. The focus of the inspection on May 24 was to check operator's <br />progress in completing rill and gully repair work as required for abatement of NOV CV-2003 <br />014, Focus of the inspection on the morning of May 25 was to assess the significance of <br />slumps on highwall reduction slopes in the "D" Pit and "A" Pit areas, and the Pond 016A <br />inslope, and consider appropriate remedial measures, Roy Karo of SCC was present on the <br />inspection both days. On May 25, DMG engineer Byron Walker participated in the <br />inspection to observe and assess the slide areas. John Pellicer, a consulting engineer with <br />MWH, consultant to Seneca Cbal Company, was also present on the May 25 inspection. <br />Weather on the 24`" was overcast with intermittent light rain showers. Weather on the 25`" <br />was partly cloudy and cool. <br />NOV CV-2003-014 Abatement Compliance <br />The extended abatement deadline for NOV CV-2003-014 is June 19, 2004. Substantial <br />progress had been made since the previous inspection, and work was continuing. It <br />appeared that all of the old breached contour ditches in the "A" Pit reclamation had been <br />properly eliminated, and that most if not all of the hillslope gullies in the "A" Pit Area had <br />been graded and topsoiled. Grading had been properly completed along the upper segment <br />of 005 Gulch that had eroded, and was subject to the NOV, and a series of 13 rock check <br />dams had been installed along the drainage, to moderate flow and facilitate vegetation <br />establishment. Work had been initiated on various other permanent channel segments <br />subject to the NOV, but some grading and riprap installation remains to be completed. <br />Hillslope gully regrading is still necessary in the immediate vicinity of Topsoil Stockpile <br />"GG", and in the lower porcions of the 005 Gulch watershed, near the "Duck Pond" stock <br />tank. Some additional grading work is necessary to fully eliminate the old temporary <br />diversion and eliminate the gully above the road culvert on 006-S1 drainage. Reseeding is <br />yet to be completed in most of the gully repair areas. <br />I[ appears that substantial progress has been made, and it appears that the operator is on <br />track and diligently working to ensure that the abatement work will be properly completed <br />by the June 19 abatement deadline. <br />Roads <br />1 Roads were wet from recent precipitation, but the roads observed appeared to be <br />properly maintained. <br />~ The "G" Road outlet ditch, which conveys road drainage into the undisturbed segment <br />of the 005 stream channel just upstream from Stock Tank T-22, had been properly <br />regraded and large riprap had been installed. <br />