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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 />Backfilling and Grading <br />Wadge Pit backfilling is ahead of schedule and Wolf Creek backfilling is contemporaneous. <br />No new slides or slumps (or re-initiation of slumping in previous slide repair areas) were <br />observed on final graded areas. Permanent drainage channel construction has been <br />completed in the "A" and "B" pit areas. A couple rip-rapped drainage segments have also <br />been completed on the east side of the regraded ridgeline, in the Pond 015 watershed. <br />Rough grading has been essentially completed in the Pond 17 watershed Wadge Pit area, <br />but the permanent channels in this area have not yet been constructed. Additional grading <br />had been completed in this area since the previous inspection, in order to establish the <br />design drainage profile in preparation for channel construction. Some additional grading <br />work appears to be necessary along the lower segment of the spoils to establish the profile. <br />The final segment of the primary channel in this location will extend from the lower end of <br />the graded spoils, across a short segment of undisturbed slope down to Hubberson Gulch, <br />above Pond 017. Work on this final segment will not be initiated until PR-5 is approved. <br />Based on PR-5 proposed postmine topography, final graded slopes in several areas will <br />exceed 30%, including Wadge highwall reduction slopes along the upper pit segment in the <br />Pond 016 watershed, final highwall reduction slopes in the Pond 017 watershed, and spoil <br />and pit endwall slopes along the divide between the Pond 016 and Pond 017 watersheds. <br />Several abney level measurements were taken in rough graded pit endwall areas along the <br />°~-~ divide, indicating slopes of 30% to 35%. Rough graded highwall slopes in the Pond 017 <br />watershed were not measured, but appeared to be consistent with the PR-5 proposed <br />grades, slightly exceeding 40%. Appropriate stability analyses demonstrating compliance <br />with applicable requirements of Rule 4.14 will be required, for the steep slope reclaimed <br />areas. <br />Topsoil <br />Topsoiling operations had resumed since the previous inspection, and additional topsoiling <br />had been completed in various locations, including slopes adjacent to the recently <br />constructed segment of the Ridgeline Access Road, and final graded areas in portions of the <br />north segment Wadge Pit in the Pond 016 watershed. In this latter area, live topsoil <br />stripped in advance of Wolf Creek pit operations had been directly replaced. <br />Revegetation/Reclamation Success <br />There is a dense infestation of the noxious weed black henbane in the vicinity of the lower <br />stock pond in the "D" pit area, as described in previous inspections. The dense, primary <br />infestation was successfully treated with herbicide, and the plants did not produce mature <br />seed. However there are scattered "outlier" plants in various other locations within the <br />