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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 />dependent on the timely initiation and successful implementation of highwall mining at <br />Yoast. <br />The extent to which DMG can accommodate these requests and considerations is <br />not clear, and a meeting of appropriate SCC and DMG staff and management may be <br />warranted, in order to avoid any uncertainty regarding DMG enforcement of reclamation <br />task deadlines set forth in the approved permit, pending review of the referenced TR and PR <br />applications. <br />Stabi/ization of Ril/s end Gu//ies <br />The rill and gully stabilization plan of the approved permit specifies submittal of a rill and <br />gully survey map by June 1 of each year that identifies the rill and gully areas, "...along <br />with a rill and gully stabilization plan that briefly describes the problem at each identified <br />area and the proposed mitigative measures." Permit narrative describes generalized <br />stabilization approaches for excessive erosion within "improved channels", slopes with "no <br />defined channel", and headcutting stabilization. The permit specifies that stabilization work <br />will be completed by November 1 each year. <br />The required rill and gully map (actually an aerial photo) was on file at the mine office and a <br />copy was provided to the Division. The map identifies excessive erosion in various <br />reclaimed areas and brief notations on the map summarize necessary repair work. In the <br />"D" Pit reclaimed area, the survey identified several gullies in the immediate vicinity of the <br />stock pond on the 005 Gulch (the Duck Pond), that need to be regraded and revegetated. <br />In addition to these locations, excessive erosion was noted during this inspection and the <br />previous inspection in locations further up the reclaimed 005 Gulch in the 1999 reclaimed <br />area. Specifically, there is active downcutting along a several hundred foot segment of the <br />main 005 drainage channel beginning approximately 200 years up-drainage from the Duck <br />Pond. Installation of periodic rock checks or similar stabilization treatments are warranted <br />along this segment of the channel. In addition, there is a side slope gully up to 18" deep <br />that parallels the 005 Gulch permanent channel, approximately 30 feet to the north of the <br />channel. The gully runs for several hundred feet in the same vicinity of the improved <br />channel erosion described previously, before it eventually ties into the improved channel. <br />Finally, close review of the aerial photo reveals apparent gullies in several locations along <br />the east facing slopes east of the ridge road within the 1999 revegetation area. This site <br />was not checked during the inspection, but should be ground checked by the operator and <br />repairs should be implemented as appropriate. <br />In the "A" Pit reclaimed area, the survey map identifies a segment of previously constructed <br />permanent channel in the lower portion of the 006 NE-1 Gulch that requires grading and <br />riprap placement. Several other gullies in defined channels are delineated in valley locations <br />further to the south where channel stabilization work needs to be completed. The map also <br />identifies several hillslope gullies up to several hundred feet in length that are described as <br />"1 + ft. Gullies Regrade & Revegetate As Necessary". The 6 gullies delineated are on steep <br />slopes reclaimed in 1997. Inspection revealed several additional gullies in the same general <br />