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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 />The final well abandonment work is to be completed at this location this summer, in accordance with State <br />Engineer directive. A minor revision application addressing the specifics of this plan, with appropriate <br />narrative and drawings (e.g. excavate and cut off casing below grade, fill excavation with concrete, <br />install rock drain, regrade, topsoil and reseed) will need to be submitted to the Division promptly. <br />Backfillina and Gradin <br />General <br />Backfilling and grading work has been completed, with the exception of full reclamation of certain roads and <br />width reduction grading of other roads to be retained for the postmine land use, along with some final permanent <br />channel grading, and maintenance grading including rill and gully repair, channel repair, and slide repair. Large <br />scale grading work has not yet been initiated this year at II-W. <br />A former scraper road extended from Stock Pond T-5 to the north, crossing Channel 006-E1. Segments of the <br />road on either side of the 006-E1 channel have not been fully eliminated, and flow concentration along the <br />remnant road segments has caused gully erosion in the past. Additional minor grading and topsoiling is <br />necessary to tie the remnant road segments into the adjacent topography, and eliminate the remnant cut <br />slope and road bed segments. <br />Rill and Gully and Slide Repairs <br />Repair of minor rills that can be completed with tractor and seed drill had recently been initiated, but significant <br />work remains, including repairs that will require larger equipment. Many of the rill and gully, and slide features <br />(including minor slumps and settling cracks, the 2006 Ridgeline Slide that requires further work, the 2007 <br />Ridgeline Slide NOV area that requires further abatement work, and the 2007 slide east of Pond 016A) that will <br />need to be repaired are delineated on the 2007 Rill and Gully Survey Map. However, several features that <br />apparently not delineated on the map, but which warrant repair, were noted during the inspection, <br />including the following: <br />• Several gullies remain in the lower part of the watershed tributary to Channel 006-NE2. Past <br />stabilization measures have included construction of small channels to handle and direct runoff. The <br />constructed channels (particularly the western channel tributary to 006-NE2) exhibit active down-cutting <br />in some locations, and there are some tributary rills and gullies that also warrant stabilization. <br />• From a distance, there appeared to be at least one significant gully running down the steep reclaimed <br />outslope of the minor valley feature approximately 400-500 feet east of Channel 006-NE2. <br />• On the old steep road segment extending from the Ridgeline Light Use Road down toward the USFS <br />aspen test plots, upper segments of the road that were previously hummocked need further repair. <br />Flows have blown out the hummocks and a gully has re-formed. Repair may need to include closely <br />spaced water bars to divert flow away from the repair area. <br />• A settling crack extending for more than 100 yards, with settling scarp up to a foot high in short <br />segments, was observed on the slope south of the upper reach of the 006 channel; east of the Ridgeline <br />Access road. This slope was subject to significant slumping and repair work several years ago. The <br />settling crack is located within the hummocked part of the slope, about 2/3 of the way up from the toe of <br />the slope. Repair to grade over the crack appears to be warranted. <br />• There are rills and gullies in various locations on the recently reclaimed northwest facing slopes of the <br />North Leg Wadge Pit. These slopes drain to Permanent Channel PM-3. None of the erosional features <br />are noted on the 2007 Rill and Gully Map, and the operator will need to inventory this location more <br />thoroughly and ensure that appropriate repairs are made. Some of the rills are associated with remnant <br />rock truck or scraper routes that were not completely eliminated, and further grading and/or topsoiling <br />will be warranted along these routes, if they have no further use. The source of other gullies is not clear, <br />but repairs are warranted. Higher drainage densities in this area may have been beneficial. A large <br />4 <br />