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111. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. Hydrologic Balancd (Cont'd) Permanent Drainage Channels Riprap installation had been completed along the lower steep segment of the 006-NE1 channel noted in the November 2004 inspection. Lower segments of the 006 Gulch and 006-NE1 channels were flowing from snowmelt runoff at the time of the inspection. Upper channel segments in the "A" Pit area, and channels draining north facing slopes were still under deep snow cover, and significant melt in these locations had not yet initiated. Along the lower end of the 006-NE7 channel, flow had skirted along the edge of the riprap in some locations, and maintenance work to re-shape the channel and re-spread and. place riprap to distribute the riprap layer evenly across the bottom and along the sides of the channel will be necessary, when conditions allow equipment access. There appeared to be some scour along lower segments of 006 Gulch in the vicinity of. the oil well .pad , and further downstream. Maintenance grading and additional riprap placement and repair will also be required in these locations.. Due to snow cover that prevented access or close observation, the condition of permanent channels in the "D" Pit area and elsewhere in the "A" and "B" Pit area could not be evaluated. Permanent channel construction has not yet been initiated in South Extension reclamation areas. The Division will conduct detailed evaluation of permanent channel compliance with approved plans this summer. Backfill and Gradin Rough backfilling and grading is continuing at an accelerated rate in the Wadge "neck pit" and the north leg pit segment within the 016 watershed. Grading in these areas has been initiated ahead of schedule, because the operator has made the decision not to implement the highwall mining approved in PR-4. As a consequence of this decision, reclamation operations have been initiated in the Wadge pit areas that had been left open for highwall mining. Anew permit revision application (PR-5) is being prepared by the operator and is expected to submitted by early April. PR-5 will address significant mine plan changes including withdrawal of highwall operations and early cessation of coal extraction (2005/2006). The revision will also include amended reclamation plan and schedule, including revision of the approved backfilling and grading schedule, postmine topography, and postmine drainage channel construction plans. At the time of the inspection, a fleet of 4 new Komatsu "375 A" dozers, plus atrack-hoe, were working backfill and grading operations in the "neck pit" area, which is nearing completion. Roy Karo said the dozers were working 24 hours a day, 6 days a week. The track-hoe was being used to pull spoil away from the perimeters of the disturbed area, to ensure that areas outside of the topsoil removal area are not disturbed during grading operations. Further to the south along the Wadge Pit, scrapers were being used to transport material from rough graded spoil areas to the base of the highwall. Highwall reduction blasting and grading had been conducted along portions of the lower segment. Backfilling and grading was previously completed in the original permit area portions of the "A", "B", "C" and "D" Pits. Lower elevation and south facing slope of the "A" and "B" pit reclamation were inspected, but remaining areas were either inaccessible or could not be observed in detail due to snow cover.