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III. COMMENTS -COMPLIANCE <br />Below aze comments on the inspection. The comments include discussion of observations made during the <br />inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br />evidence supporting the enforcement action. <br />configuration will not meet the vertical alignment requirements for light-use roads. Until <br />such time that SCC provides appropriate demonstrations for permanent retention of the <br />light-use road in the North Pit, the DRMS assumes that SCC will reclaim the road when <br />it is no longer needed. At this time, the entire length and width (including road cuts and <br />embankments) of the light-use road will be excluded from Phase I bond release. <br />A two-track road exists at the approximate location of the former haul road that led up to <br />the south end of the north pit. This two-track road branches off of the light-use road and <br />heads south up to the top of the southern end of the North Pit. When no longer needed <br />this road should be reclaimed or SCC should request to retain this section of road as <br />permanent. Appropriate demonstrations in accordance with 4.03.3(3) and 2.05.5(1) (b) <br />would be required for retention of this two-track road as a permanent light-use road. A <br />photograph of the lower portion of this road is shown in Photograph No. 2. <br />Hydrologic Balance <br />One impoundment was included in the bond release request area (Sediment Pond 11 A). <br />SCC has not requested that this pond be retained as permanent and the pond has not been <br />reclaimed. Therefore, this pond is not applicable to the Phase I bond release. If SCC <br />decides to retain this pond in the future, SCC must submit a permanent pond <br />demonstration in accordance with Rule 4.05.9 (13) and obtain written land owner <br />approval for permanent retention of this pond. <br />Three permanent post-mine drainage channels (PM-9, PM-10, and PM-13) were <br />inspected as part of this Phase I bond release to assess general design compliance. The <br />lower Armand Draw drainage was not included in this bond release application and was <br />not assessed as part of this inspection. Certified designs were approved for all post-mine <br />drainage channels prior to this inspection and aze provided in the PAP at Appendix 13- <br />12.3. The permanent channels are designed to safely convey the peak dischazge from the <br />10-year, 24-hour storm event in accordance with 4.05.3. Post-mine drainage channels <br />PM-9, PM-10, and PM-13 aze within this bond release request area. These channels were <br />inspected for function with regazd to knickpoints, blending at disturbance boundaries and <br />channel erosion. In addition to the certified designs, as-built drainage profiles (Exhibit E <br />of the bond release application package) were also reviewed and evaluated in the field. <br />The entire length of each drainage channel was walked and measurements were taken at <br />the upper, mid and lower sections of each channel for comparison with design and as- <br />built information. Channel gradients and bottom widths were measured at each drainage <br />channel to evaluate compliance with design criteria. The results of these measurements <br />are provided in the table below. <br />2 <br />