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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 />enforcement actions for 004 discharge exceeding applicable suspended solids limits. Concerns with this <br />discharge site are now moot, since mining has ceased and the North Portals have been plugged. <br />The operator collects data from a number of stream gaging stations, alluvial and bedrock monitoring wells, <br />and refuse area piezometers in conformance with permit specified frequencies. This data, in addition to <br />discharge data is compiled and summarized in annual hydrologic reports submitted to the Division. Based <br />on review of the annual reports and field observations, hydrologic impacts of the operations appear to be in <br />conformance with permit projections, with no pollution of surface orsub-surface water evident. To the <br />extent that existing and proposed drainage and sediment control structures and mine-water discharge sites <br />are installed and maintained in compliance with permit requirements, future pollution of surface or sub- <br />surface water is not anticipated. <br />(3) Stability of Reclaimed Surface Lands--- <br />Compliance with backfilling and grading permit requrements was evaluated, and visual assessment of <br />apparent stability was conducted at the following locations wherebackfilling and grading has been <br />completed: <br />The North Decline, Northwest Intake Portal, lower benches of Cameo Refuse Disposal Area No. 1 (CRDA- <br />1), lower benches of Cameo Refuse Disposal Area No. 2 (CRDA-2), South Fan site and soil borrow area, 2 <br />West Portals site, South Lease Exploration sites and roads, Cameo Borrow Area No. 1, and Topsoil Piles 5 <br />and 6 and the temporary haul road from Cameo Borrow Area No. 2 to CRDA-I. Apparent stability of the <br />various backfilled locations is addressed under Phase J Bond Release Evaluarron, Items 1 through 8 below. <br />(4) The degree of difFculry and estimated cost to complete any remaining reclamation--- <br />These factors were considered by the Division during the inspection, and were incorporated into an updated <br />reclamation cost estimate prepared by the Division as a component of the evaluation. The starting point for <br />the Phase I bond release cost estimate is the cost estimate forwarded to the operator as an enclosure to a <br />letter of July I6, 2001, which indicates a total estimated liability amount of 53,244,980.00. This bond <br />amount was agreed to by PCC with their letter dated July 27, 2001. All public comment and appeal <br />timeframes pertaining to this bond amount exp'ved on September 4, 2001, without comment or appeal. <br />Based on information provided in the bond release application and verified during the bond release <br />inspection, the following modifications to the current cost estimate appear to be warranted: <br />Items 006 through 010 have been satisfactorily completed for Phase I bond release, and can be deleted <br />from the amended cost estimate. <br />Item 023 has been satisfactorily completed for Phase I bond release, and can be deleted from the amended <br />cost estimate. <br />