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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 />A couple of permit designated "minimal disturbance' native drainage channels were walked during the <br />inspection; the channel in the 005 watershed along reduced Road "G", between Stock Pond T-20 and Stock <br />Pond T-22, and the drainage downstream to the east of the larged fenced Ridgeline shrub/tree planting area, <br />which drains into Pond 015. The 005 drainage is deeply incised along most of its length, and inspection several <br />years ago had noted indications of recent down-cutting in several locations. At present, the channel appears to <br />be relatively stable, and vegetation is becoming established along and within the channel along most of its <br />length; likely due to maturing vegetation cover and reduced runoff from the reclaimed "D" pit portions of the <br />watershed. There is some apparently recent minor down-cutting along a 150 foot segment toward the lower end <br />of the reach, immediately upstream of the point where a riprapped road outlet drain enters the channel. <br />Stabilization measures may be warranted along this segment prior to sediment pond removal, if it does <br />not stabilize within the next few years. There is a heavy infestation of Canada thistle along the drainage <br />within the minimal disturbance area, and spraying is warranted. The channel downstream of check pond <br />T-22 to Sediment Pond 005 has been riprapped in the past, and appears to be stable. T-22 is filled in, with no <br />remaining capacity for sediment retention, and vegetation is becoming established. <br />The drainage in the 015 watershed is heavily vegetated in most areas (aspen forest with tall shrub/native forb <br />understory). The channel appears to be stable, with no indications of active down-cutting or deposition. <br />Reclaimed area stock ponds T-18 in the 005 watershed and T-5 in the 006 watershed held water; T-20 at the <br />lower end of the reclaimed "D" Pit in the 005 watershed is full of sediment, and at present is in essence a <br />wetland fed by spoil springs, with a thick growth of cattails. T-25 in the 017 watershed is to be constructed this <br />year. T-22 and T-20 appear to have fulfilled their purpose for sediment retention and watershed stabilization <br />during operations and early stages of reclamation; further disturbance that would be created by sediment <br />excavation does not appear to be warranted, unless ponds are desired in these locations to support postmining <br />grazing use. <br />Soil Stockpile CCC sedimentation sump was inadvertently not checked during the inspection, but based <br />on most recent pond inspection report, sediment clean-out from the sump would appear to be <br />warranted, to restore design capacity. <br />Backfillinq 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. <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. Soil had recently been placed at the site to effect the repairs described, but the <br />grading work had not yet been initiated. <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 />5 <br />