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III. COMMENTS -COMPLIANCE ~~~ Ma-~- sfi~;~~n C~v X06 Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. Hydrologic Reclamation (Sedimentation) (cont.) -These calculations were confirmed by the Division. The calculated (estimated) sediment yield for the reclaimed Pit 1 was 0.83 Tons/Acre/Year. The calculated (estimated) premining sediment yield was 2.30 Tons/Acre/Year. This gives an estimated postmining sedimentation yield of 35% of the premining yield. The criterion for sedimentation for this area has been met. The inspection confirmed the calculations. With the exception of the exclusions noted above, there was no noticeable erosion on the reclaimed Pit 1 and both of the ditches (PD3 and PD4) did not appear to contain any sediment. There also did not appear to be any sediment being deposited at the inlet of the culvert running under the road. The areas that have been excluded from this bond release did not appear to be contributing sediment to the other areas of Pit 1. Phase I Bond Release for the Loadout The Operator is requesting a 60% ($8,472.00) Phase I Bond Release for the Loadout. The total cost for reclamation of the Loadout was $14,120.00. The reclamation for this area (backfilling and regrading) was completed in 1999. The criteria that were observed were backfilling, regrading and drainage control. Backfilling/Regrading -The area of the loadout that was backfilled and regraded (not including the permanent access road and facilities area) appear to have been completed in accordance with the approved reclamation plan. A comparison of premining and postmining topography maps (Map 35 and Drawing No. 2, respectively) and premining and postmining cross-sections (Map 39 from July 1989 and Map 39 from May 2001, respectively) shows that the Operator has achieved Approximate Original Contour (AOC), in accordance with Rule 4.14.1(2)(a). The inspection confirmed that AOC has been achieved. Although the area is (and was) relatively flat, there was a small hill in the Southeast portion of the Loadout that has been reestablished. This hill is depicted in cross-section A-A'. During the inspection there did not appear to be any cracks or other problems associated with the backfilling and regrading of the Loadout area. Drainage Control -The drainage and sedimentation control at the regraded Loadout consists of ditches, berrns and a sediment pond. There is an irrigation ditch along the Northeast side of the Loadout, to keep runoff from the undisturbed areas off of the reclaimed area. There is a second ditch along the Southwest side of the Loadout to route water from the reclaimed area and any potential runoff from undisturbed areas to the sediment pond. This ditch also keeps runoff from the undisturbed areas off of the reclaimed area. There is a permanent berm (or series of berms) around the reclaimed area that helps keep runoff from the undisturbed areas from reaching the reclaimed area. The final drainage and sediment control feature is the sediment pond. All runoff from the reclaimed area is routed through ditches into this pond. The inspection confirmed the existence of all of these drainage and sediment control features and confirmed that they were functioning properly.