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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 />vicinity that also require stabilization. Most of these hillslope gullies appear to have been <br />caused or exacerbated by old erosion control ditches that have breached, resulting in <br />concentrated runoff and sequential ditch failures down-slope. In this general area, it is <br />important that, in addition to regrading and revegetating the gullies, the old erosion control <br />ditches need to be blocked/breached at closely spaced intervals to eliminate the <br />concentrated flows that have resulted in sequential breaching and erosion. A similar <br />hillslope gully approximately 600 feet in length (actually two feeder gullies that combine <br />into one primary gully) was observed in a 1995 reclamation area, several hundred feet <br />northeast of Topsoil Stockpile P2. This gully is also associated with breached erosion <br />control ditches. The gully needs to be regraded and revegetated, and the old erosion <br />control ditches in this area also need to be blocked/breached at closely spaced intervals to <br />prevent concentrated flow. <br />Erosion control ditches similar to those that contributed to the excessive gullying are no <br />longer an approved component of the soil stabilization/seedbed preparation plan. The <br />currently approved seedbed preparation plan states that rep/aced soi/s on slopes steeper <br />than 25% wi/l be pockmarked with dozer dips or track-hoe humps. <br />Although not checked during the inspection, subsequent review of the survey photo <br />revealed several apparent gullies that may require stabilization within a 1996 revegetated <br />area, a short distance to the south of Topsoil Stockpile GG. <br />Finally, an area of headcutting erosion located along the southern perimeter of the "A" Pit <br />disturbance area, below the dragline tub facility site was previously described in the June <br />inspection report. Stabilization measures have not yet been implemented. <br />The operator needs to initiate necessary rill and gully repairs promptly, and complete all <br />necessary repairs, including work to prevent concentrated flow associated with erosion <br />control ditches, by November 1, 2003. Repairs need to be completed within all locations <br />identified on the 2003 Rill and Gully Survey map, the additional areas described in this <br />report, and any additional areas of excessive erosion on reclaimed areas that may have been <br />missed in the original survey and not observed during this inspection. <br />Miscellaneous BackTrlling and Grading <br />There is a minor scarp several hundred feet in length associated with a slide along the <br />graded highwall on the southern perimeter of the "A" Pit area, east of the powerline. The <br />slide area will need to be regraded to eliminate the scarp prior to topsoiling this fall. <br />Permit Revision No. 3 (PR-3) became effective in June 2003. Relatively large expanses of <br />spoil regraded prior to PR-3 approval were graded to a relatively smooth surface. PR-3 <br />includes the following provision, which is intended to result in increased topographic <br />variation on the final graded surface. /n the future a// backfi/led spoi/s wi// be graded to <br />create irregular topographic undulations. To date, this provision has not been implemented, <br />because no final grading has been completed since PR-3 was approved. <br />