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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 />The roadside ditch at the southeast corner of the waste disposal area topsoil stockpile needs to be <br />cleaned out, and the berm separating the road ditch from the topsoil stockpile containment ditch needs <br />to be built up. <br />Old culvert segments and well casing segments have been left in place along the road near the <br />sediment pond, and need to be removed and properly stored or disposed of. <br />The temporary drill pad access road up the North Fork of Munger Creek has been reclaimed (see April 23, 2006 <br />inspection report for details). Evidence of seeding was not apparent along the initial segment of the road in the <br />Munger permit area, between the portal access road and the initial crossing of the. North Fork of Munger Creek. <br />Seeding is necessary and should be conducted during the summer (mid July -mid August) seeding <br />period. <br />Hydrologic Balance <br />There was flow in East Salt Creek, but not in Munger Creek <br />At the portal area, SAE-1 sed+ment control rock check structure was intact and functional. The sump area was <br />dry. Silt fences directly east of the rock check require some maintenance. The lower-most silt fence at <br />SAE-1 is in good condition, but the upper silt fence segments need to be maintained. In a couple locations the <br />fencing is not properly trenched in, and needs to be re-trenched and secured. <br />At the west end of the portal area, the diversion ditch that directs upland flow away from the bench area and <br />conveys flow to the 48" upper road culvert was recently excavated along the lower segment as appropriate. <br />Large rock needs to be placed along the steep eroded segment of the ditch, a short distance upstream <br />from the excavated segment. <br />At the waste disposal site, the surtace casing of monitoring well GW-6 appears to have been properly replaced. <br />Refuse area sediment pond was dry, sediment level 12" to 18" below the level of the gated primary spillway pipe <br />inlet. <br />Backfill and Grading <br />There was no evidence of new erosion on the interim reclamation fill on the mine bench area, and no evidence <br />of renewed cracking, caving, or sloughing. Areas of the fill which had been affected by caving on top of the fill <br />and surficial sloughage on the outslope were properly graded, seeded, and mulched last fall. Seeded grass has <br />germinated and initial establishment appears to be satisfactory. <br />Processing Waste <br />It did not appear that additional waste had been placed in the disposal area since the April 2006 inspection. The <br />material has been graded in an approximately level layer across the initial disposal cell. Prior to disposal of <br />additional material (and prior to the end of June 2006), the disposal will need to be inspected and <br />certified by a professional engineer, and necessary compaction testing will need to be conducted. <br />Soil sediment material removed from the disposal area sediment pond last fall and stored on top of the cover soil <br />stockpile has been properly ripped and graded. The graded area needs to be seeded with the stabilization <br />seedmix, and mulched with properly anchored, certified weed-free straw. Seeding/mulching should be <br />conducted during the summer (mid July -mid August) seeding period, to take advantage of typical late <br />summer/fall precipitation, and to provide some erosion protection from intense summer/fall rainstorms. <br />Seedbed preparation tillage should be completed in conjunction with the seeding. <br />4 <br />