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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 /> Hydrologic Balance <br /> Drainage and sediment control structures were in general properly maintained and functional. Silt fencing and <br /> berms at the various small area exemption sites were for the most part intact and functional, however <br /> maintenance is necessary to repair or replace silt fence installations at the following locations: <br /> • "B" Substation north side silt fence was ripped along the center stake; needs to be replaced. <br /> • 2W Portals upper portal backfill silt fence was undercut at the end near creek channel; needs to <br /> be repaired. <br /> 2W stockpile area(between reclaimed portals)silt fence had pulled off stakes in a couple <br /> • locations, and needs to be re-stapled. <br /> All sediment ponds and SAE sumps were dry, with the exception of Pond 1&2, which contained shallow puddles. <br /> Some fill material had been placed in Pond 8 at the South Portals area, in association with the pond size <br /> reduction approved in Permit Revision 3. Construction of the smaller Pond 8 will be completed in conjunction <br /> with the current South Portals area reclamation project. <br /> The 016 mine discharge site was flowing at the normal rate(approximately 300 gpm); flow was clear. <br /> Drainage and diversion ditches and permanent diversion segments were in most cases in good condition. The <br /> problem of recurrent erosion along the"explosives bunker' permanent channel segment was noted in the <br /> previous complete inspection. Subsequently,the operator submitted a technical revision design plan for the <br /> segment of concern, which has been approved by the Division. The design is to be implemented prior to May <br /> 2008. <br /> French drain installation in the immediate highwall backfill area was previously completed. The 001 discharge <br /> dewatering pipe has not yet been sealed; a hose has been extended out from the buried pipe and water from this <br /> source is being used for dust suppression during earthwork operations. This pipe will be plugged with pumped <br /> concrete grout in accordance with specifications in recently approved TR-53, as a component of the South <br /> Portals reclamation project in progress. <br /> The RSRDA diversion segment that had been impacted by rockfall as noted in the previous site inspection had <br /> been repaired. <br /> The South Portal area drainage system, including various road ditches, culverts, diversion channels, and <br /> Sediment Pond 8,was altered by Permit Revision 3 (PR-3) designs. Installation of the PR-3 approved drainage <br /> system is in progress, in conjunction with the South Portal area reclamation project currently under way. All <br /> disturbed area drainage in the South Portal area continues to be properly routed to Sediment Pond 8. <br /> Backfilling and Grading <br /> The various backfilled and graded areas were walked, and no excessive erosion, slumping, cracking, or other <br /> signs of instability were apparent. Backfilling and grading associated with the South Portals reclamation project <br /> is continuing. Concrete demolition was continuing but appeared to be nearing completion in the former wash <br /> plant location in the lower facilities area. Soil from the UTL had been stockpiled for spreading over final graded <br /> surfaces in the lower facilities area. The soil appears to be a reddish brown sandy loam. <br /> Processing Waste <br /> Most areas of the CRDA-1 and RSRDA waste disposal sites site were walked, and the reclaimed CRDA-2 was <br /> viewed from the top of CRDA-1. There were no indications of instability or excessive erosion. Diversions, <br /> perimeter ditches, and terrace drains appeared to be properly maintained and functional. <br /> 4 <br />