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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 />Roads <br />Roads appeared to be properly maintained, although a detailed and comprehensive <br />inspection was not made. Construction of road K was continuing. Topsoil salvage and <br />stockpiling associated with the road construction appears to have been properly conducted. <br />Maintenance of the segment of HR-A ditch down-gradient from the shop area appears to <br />have been conducted as requested in the previous inspection. <br />Backfilling and Grading <br />Rec/ametion Progress <br />Reclamation Schedule General Permit Requirements <br />Several sections of the approved permit address reclamation scheduling, including <br />commitments pertinent to contemporaneous reclamation. The Reclamation Timetable in Tab <br />19 specifies that backfilling and grading is a year-round activity, while other reclamation <br />tasks are to be conducted within defined time-frames. Topsoil redistribution is conducted <br />mid-May through mid-November (and other times weather permitting, according to the <br />table). Perennial seeding is conducted mid-August through mid-November (through the end <br />of November and during April and May weather permitting). <br />Tab 19 "Reclamation Scheduling" text states that topsoil is to be replaced within one year <br />after final grading is completed, and permanent seeding is to be accomplished in the first <br />appropriate planting season following topsoil replacement. <br />The timeframe for construction of postmining drainage channels is not specifically defined in <br />the approved permit. Logically, drainage channel construction including riprap installation <br />needs to be completed as soon as possible following spoil grading, in order to minimize <br />erosion of-the regraded drainages. Further, channel construction needs to be completed <br />prior to replacement of topsoil adjacent to the drainages, in order to avoid excessive <br />compaction or other disturbance to the replaced soil. As such, permanent channel <br />construction needs to be completed within one year, at most, following final spoil grading <br />within a reclamation parcel. <br />D"Pit Area Reclamation Status <br />"D" Pit Area spoil grading was completed in the fall of 2002. Approximately 60 acres of <br />the "D" pit was final graded in 2001 and 2002, and this acreage has not yet been topsoiled <br />and seeded. A somewhat larger area of "D" Pit graded spoils had been topsoiled and <br />seeded in 1999. <br />There are two designed permanent drainage channels in the "D" Pit reclamation area; 005 <br />Gulch and 005 E-1 Gulch. Upper segments of 005 Gulch (above the "Duck Pond" stock <br />