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Faye <br />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 />evaluating backfill and grading release requirements and approximate original contour <br />restoration. The DRMS Proposed Decision and Findings of Compliance for the Phase I Bond <br />Release aze forthcoming. If TR-37 is not approved by the time the proposed decision is issued <br />these structures will be excluded from release of Phase I bond liability. <br />Roads <br />There aze approximately 13.5 miles of haul roads that were retained as permanent roads. These <br />sections of haul roads were converted to access roads. Permanent roads aze discussed in the <br />permit application package (PAP) on page 13-52. All other operational road sections other than <br />those listed below have been fully reclaimed. SCC has retained the following designated roads <br />as permanent: Pre-Law Road, Road C, Road E, Road El, Road F, and South Road. These roads <br />are shown on Exhibit 13-2A, post-mine permanent road cross-sections are presented in Exhibit <br />13-2B, and permanent road profiles aze shown on Exhibit 13-2C (all of these exhibits aze <br />pending approval of TR-37). The following actions were completed to convert the operational <br />haul roads to post-mine access roads: 1) The top road surface was narrowed to approximately <br />twenty feet, 2) The road surfacing material from any narrowing of a section was placed on the <br />remaining road width; and 3) All azeas re-disturbed byroad narrowing activities were re-seeded <br />to the edge of the road surface. <br />Permanent roads were narrowed to the present configurations and road edges seeded following a <br />DRMS inspection that focused primarily on the proposed permanent roads in June 2005 (see <br />inspection report dated 06/30/05). Road narrowing and reconfiguration was completed by the <br />fall season of 2005. <br />Since permanent roads aze considered part of the post-mining topography and final grade, all <br />permanent road sections were evaluated and inspected as part of this Phase I bond release <br />inspection. The inspection consisted of visual inspection of the entire road length for each <br />permanent road. The width of road surface and the percent grade along road profiles at select <br />locations were measured. The locations of width and percent grade measurements taken during <br />this inspection are the approximate same locations shown on Exhibit 13-2A for the as-built road <br />cross-sections. <br />As-built information for permanent roads was verified. All of the measurements taken were <br />consistent with the as-built data provided by SCC. The as-built road cross-sections for all <br />permanent roads indicate a road width of 20 feet with exception of Road E where the as-built <br />width at section E-E' is given on Exhibit 13-2B as 24 feet. All grades measured along road <br />profiles were below the maximum road grades required by Rule 4.03.2(3). The measurements <br />