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III. COMMENTS -COMPLIANCE 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. conducted by DMG and BLM, it was determined that no further inspection of the sites was warranted at this time. Further, based on those inspections and BLM's satisfaction with the reclamation conducted, it is my conclusion that drill hole sealing, drill sitebackfilling, and drill site access road regrading associated with sites PCC-01 through PCC-10 was satisfactorily completed and qualifies for Phase I bond release. One additional drill site (GWMS-03) waz approved under the South Lease Exploration Plan, and the drill hole was sealed. However two additional monitoring wells were drilled at this location, and reclamation of this site will not occur until the monitoring is terminated and the wells (GWMS 03a and 03b) are sealed (see Item 56 of the current cost estimate). CRDA-1 and CRDA-2 For a number of reasons, the Division will not propose to approve Phase ]bond release for the reclaimed CRDA•1 and CRDA-2 benches at this time. As discussed below, the construction and non-toxic cover placement for the lower three benches of both refuse piles appears to have been completed in compliance with permit requtrements. However, regrading and cover placement on the upper two benches and final grading of the upper terrace drains, rip-rapping of upper segments of the permanent perimeter ditches, and certain other regrading tasks have not been completed. Rule 3.03. I (2)(a) specifies that, for Phase I bond release, "[U]p to sixty percent of the applicable bond amount shall be released when thepermittee successfully completes backfilling, regrading, and drainage control in accordance with the approved reclamation plan" The Division's interpretation of this rule for refuse piles, is thatregrading, cover soil placement, and installation of final drainage controls for the entire refuse pile must be completed prior to Phase l bond release for the pile (or portion of a pile). Until the enCve pile and associated permanent drainage system has been completed, there is the potential for erosion and sedimentation from bare refuse areas and unfinished upper perimeter ditch segments to impact lower portions of the refuse pile diversion and collection system, including the terrace drains. This increazes the potential for sediment deposition and erosion on reclaimed benches. Deposition ofcoaly sediments or erosion of the reclaimed benches or lower ditch segments would necessitateroitigative work on the completed areas. th the specific case of CRDA-l, final grading of the upper two benchoutslopes and tertace drains has not been completed, upper bench terrace drain outslopes are over-steepened in some locations, the upper two benches have not been cover-soiled, and upper segments of the permanent perimeter ditches have not been riprapped. Essentially the same situation existed at CRDA-2. U addition, on CRDA-2, a temporary haulage road angles across the face of the pile, and completion of final terrace drains on the reclaimed benches in accordance with approved final designs cannot be performed until the road has been reclaimed. Further, at CRDA-2, the Division has identified concerns with the suitability of the existing upper diversion as a permanent structure, and a new upper diversion is to be completed az a component of CRDA-2 final reclamation. Given the possibility that the Division's proposed decision to deny Phase I releaze for the refuse areaz based on the above interpretation ar:d reasoning may be appealed, an evaluation of construction compliance and apparent stability of the reclaimed lower benches was conducted. During the bond release evaluation, DMG requested additional documentation of compliance with construction and reclamation requvements associated with the reclaimed benches of CRDA-1 and CRDA-2, for which Phaze l bond release was requested. Adequate docwnentation was provided.