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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 />DMG engineer Byron Walker. None of the slide features appear to represent imminent <br />threats to public safety or the environment, however certain remedial measures and <br />investigations are warranted. Observations are summarized here below; a more detailed <br />assessment will be prepared by Byron Walker and forwarded to the operator. <br />The first area observed was the north facing slope to the south of the upper 005 <br />drainage segment extending from the vicinity of the "Duck Pond" stock tank, to the <br />eastern ridgeline. There are cracks and small scarps extending along much of the <br />length of this slope, apparently along the crest of the backfilled final highwall, and most <br />likely caused by settling of spoil in the backfilled pit. The slope was initially <br />revegetated in 1999, and it would appear likely that most of the settling occurred <br />shortly thereafter. Scarps are mostly 6 to 12 inches high, up to 18 inches in a few <br />locations. In most areas, cracks appear to have largely filled in and vegetative growth <br />is beginning to obscure the settling features. The operator directed a dozer to perform <br />some grading along a segment of the crack/scarp feature at the east end of the slope <br />during the inspection, and indicated that further grading was planned along the length <br />of the slope to seal over remaining open cracks. This measure may be warranted to <br />minimize surface infiltration, which could possibly trigger further movement. <br />Q The second area observed was the landslide on the steep north facing final highwall <br />reduction slope on the southern boundary of the "A" Pit area. The scarp is over 8 feet <br />high and extends for several hundred feet. Byron Walker described the slide as a <br />classic rotational failure. The slope is scheduled to be topsoiled and seeded this fall, <br />and regrading to eliminate the scarp and associated cracking will obviously be required <br />prior to topsoiling. Further measures, including reduction of the slope gradient by <br />lowering the crest of the ridgeline in the vicinity of the slide, may be warranted to <br />ensure a stable configuration. The operator is directed to prepare and submit a <br />technical revision slide remediation plan, which will address measures that will be taken <br />to repair the affected slope and ensure a stable slope in conformance with Rule <br />4.14.211)Ibl• The plan is to be submitted promptly, to ensure that final reclamation of <br />the slope, including topsoiling and re-seeding can be completed in the fall of 2004. <br />6 The third area observed was Pond 016A. The in-slope slide features do not appear to <br />have worsened noticeably since the previous inspection. Due to the fact that the lower <br />portions of the slumps are submerged beneath the surface of the water in the pond, it <br />is not possible to determine whether the design storage capacity of the pond may have <br />been compromised. <br />The operator is directed to safely lower the water level of the pond or take other <br />measures as necessary to accurately determine the existing pond capacity. If the <br />approved design capacity is compromised or if slide repairs are otherwise determined to <br />be necessary, a technical revision plan for remediating the slide and restoring the pond <br />capacity will need to be submitted to the Division by July 1, 2004. <br />4 <br />