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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 />shadow and remnant snow cover in some locations prevented detailed observation. Minor grading work <br />was recommended in the previous report to re-direct runoff in certain locations on slopes to the north and <br />east of the oil well pad. It could not be discerned whether this work has been completed. However, <br />given that snow appears to have only recently melted, it is likely that equipment has not yet been able to <br />access these locations, and the work will need to be completed when conditions allow. There appeared <br />to be minor channel erosion in lower sections of 006 and 006-NE1 permanent channels. Grading and <br />riprap repairs will likely be necessary along these segments. Additional riprap may also be warranted <br />along the Pond 006 inlet segment below the Culvert Al outfall. <br />Backfill and Grading <br />Current Project Areas <br />Significant progress has been made with respect to backfilling and grading since the previous inspection <br />within the Wadge ridgeline or "neck pit", the north leg pit segment within the 016 watershed, and the <br />southern-most segment of the Wadge Pit within the Pond 017 watershed. Backfill and grading of South <br />Extension Area Wadge Pits has been initiated ahead of schedule, because the operator has made the <br />decision not to implement the highwall mining approved in PR-4. As a consequence of this decision, <br />reclamation operations have been initiated in the Wadge pit areas that had been left open for highwall <br />mining. Anew permit revision application (PR-5) is being prepared by the operator and is expected to be <br />submitted this month. PR-5 will address significant mine plan changes including withdrawal of highwall <br />operations and early cessation of coal extraction (2005/2006), The revision will also include amended <br />reclamation plan and schedule, including revision of the approved backfilling and grading schedule, <br />postmine topography, and postmine drainage channel construction plans for the South Extension Area. <br />At the time of this aerial inspection, the fleet of 4 new Komatsu "375 A" dozers were conducting rough <br />backfill and grading operations in the Pond 17 Wadge Pit area. Final grading in this area is scheduled for <br />completion in 2007, under the current permit. Spoil ridge material had been pushed down along the <br />length of this pit. The highwall had been eliminated along the upper third of the pit, and rough grading <br />had been completed within the upper pit area. Neck pit rough grading appears to have been essentially <br />completed within the 2005 grading deadline area since the March inspection (2003 and 2004 grading <br />deadline areas were previously completed). Substantial backfilling has also been accomplished in the <br />north leg Wadge Pit (2006 grading deadline), with highwall substantially eliminated along the length of <br />the pit, and spoil ridges pushed down. Substantial backfill and grading remains to be done within this pit <br />area, and at least one scraper and a dozer were working in this location at the time of the inspection. <br />Backfill and grading is substantially completed at the south end of the south leg Wadge Pit (2004 grading <br />area) and has been initiated at the north end (2006 grading area). The middle segment of this pit (2007 <br />grading areal remains open, with minimal backfilling initiated. <br />Backfilling and grading was previously completed in the original permit area portions of the "A", "B", "C" <br />and "D" Pits. <br />Rills and Gullies <br />It could not be determined with certainty whether rill and gully stabilization and associated minor <br />regrading work had been conducted on recently reclaimed slopes in the vicinity of the oil well pad, as <br />recommended in the March inspection. Because additional snowfall occurred shortly after that <br />inspection, and snow cover had only recently melted, it is likely that the work had not been conducted <br />prior to the aerial inspection. <br />4 <br />