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IV. OBSERVATIONS AND FINDINGS <br />Drillhole SealinH and Reeradine of Disturbed Areas <br />Backfilling and regrading consisted of grading stockpiled topsoil and subsoil over the drillhole pads <br />and access roads. The most regrading was necessary where pads had been cut by a dozer several feet <br />into the hillside. Forty-one drillholes were drilled in the bond release area when the land was <br />disturbed in 2000. Numerous locations of these drillholes were examined during the bond release <br />inspection. At each location well surface casing was not visible, consistent with having been cut off <br />below the ground surface. The location of each drillhole was marked on the ground surface with a <br />brass cap. The drillpads and access roads had been regraded to blend in with the sursounding tersain, <br />resulting in hillslopes closely resembling the approximate original contour. A slope stability analysis <br />submitted by the applicant indicated the reclaimed slopes satisfied the static safety factor requirement <br />of 1.3. Based on the close resemblance to approximate original contour, the Division finds the <br />operator has completed regrading in accordance with the approved reclamation plan. <br />DrainaEe Control <br />Drainage in the bond release area currently is managed as a "small area exemption", as allowed by <br />Rule 4.05.2(3). As an alternative to the ponds or treatment facilities required by 4.05.2(2), straw <br />mulch and (formerly) silt fences have been employed as sediment control methods. Runofffrom the <br />bond release azea would occur as sheetflow on hillslopes because slope lengths are no greater than a <br />few hundred feet. The runoff would concentrate into channelized flow in the natural drainages <br />located downhill from the bond release area. Positive drainage appeazed to exist within the bond <br />release area and along the drainage route from the bond release azea to the natural drainages. No <br />signs of erosional instability were found in the bond release area. No sediment fans or gully erosion <br />were evident. Based on the observations made during the inspection, the Division finds that the <br />operator has completed reestablishment ofdrainage in the bond release azea in accordance with the <br />approved reclamation plan. <br />Hydrolo¢ic Impacts <br />In accordance with Section 3.03.2(2), the Division has evaluated whether pollution of surface <br />or subsurface water is occurring, and the probability of future occurrence of such pollution. <br />The evaluation considered information in the Probable Hydrologic Consequences section of <br />the permit application, Annual Hydrology Reports submitted by the operator, and the <br />Division's Annual Hydrology Report review memoranda. <br />Limitation on Release Amount Request <br />Phase I bond release is being requested for the bond release area. The applicable bond amount for <br />the Thermal Event Area is $132,879 (Memorandum from Jim Stark to Dan Hernandez in SL-1 file, <br />dated October 6, 2005). Section 3.03.2 restricts the amount of bond that is eligible for release in a <br />Phase I release to 60% of the applicable bond; therefore, 60% of the applicable bond, or $79,727, is <br />eligible for release, assuming all other bond release requirements are met. <br />