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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 /> Backfill and Grading <br /> Backfilled slopes along the access road and in the portal area held up well, with only minor rill erosion in some <br /> areas, most concentrated along lower slopes in the portal area and along dome of the long slopes adjacent to <br /> permanent channels along the reclaimed road. There were also short remnant gully segments immediately <br /> below the silt fencing at the lower end of Channel "H". Riprapped permanent drainage segments functioned <br /> well, with no evident erosion or siltation along their length, or at inlet/outlet locations. <br /> Based on observations I made on the morning of November 19,some rill and gully repair work is <br /> warranted along the longer rills on the portal backfill, below the Channel "H" lower silt fences, and in a <br /> few locations along the reclaimed portal access road (including a gully on the eastern sideslope above <br /> Channel "D"). <br /> There were no indications of slope instability(cracking, slumping, etc.)along the reclaimed road or on backfill <br /> slopes in the portal area, when these sites were inspected on November 19. <br /> Processing Waste <br /> The waste disposal site(including the waste disposal cell and adjacent cover soil and topsoil stockpiles) had <br /> been seeded with the permanent mix and straw mulched shortly before my inspection on November 19. No <br /> problems were evident; the site appears stable with no appreciable erosion. <br /> Topsoil <br /> Backfill slopes in the portal bench area and waste disposal area (waste cell and cover soil stockpile area)were <br /> properly topsoiled during the June/Julyi 2007 reclamation project. The lower road topsoil stockpile was fully <br /> used up, and the stockpile footprint area was graded, roughened and seeded with "Quickguard"cover crop. A <br /> small quantity of topsoil remains in the waste disposal stockpile site, to be used for final reclamation of the <br /> sediment pond site when the pond is filled in. The remaining soil in stockpile was spread out, roughened and <br /> seeded with the cover crop. There is also a small remnant pile of cover soil (subsoil) material in stockpile <br /> adjacent to the sediment pond that will be used for final backfilling of the pond. The remnant topsoil stockpile <br /> and lower road stockpile area footprint had been seeded with the permanent mix and straw mulched shortly prior <br /> to my inspection of November 19. <br /> Revegetation <br /> As noted in the October inspection report, the"Quickguard" cover crop that was seeded in July on areas that <br /> were graded and roughened in association with the reclamation project had established a moderate cover, with <br /> plants averaging 4 to 6 inches in height in most areas. There had been further growth since early October, and <br /> a number of the plants had produced sterile seedheads by November 19. It was noted that in areas along the <br /> lower road that had not been fenced, the cover crop had been heavily grazed by deer and cattle. Cattle were <br /> present along the lower road area on November 29 and deer sign was abundant on both dates. <br /> Permanent seeding and straw mulching had been largely completed prior to my inspection of November 19. <br /> Daniel Brandstadt of High Country Equipment, the seeding contractor, was on site with a small crew finishing up <br /> the mulch distribution and some spot seeding on the 19th. Apparently, none of the mulched areas had been <br /> crimped (Mr. Brandstadt said that lower road areas that were mulched while he was on the project had not been <br /> crimped; he had not been on site when upper road areas and the portal bench area were mulched). From my <br /> observations, it did not appear that upper road areas or the portal bench area had been crimped. I discussed <br /> the fact that these areas would need to be crimped as specified in the approved permit with Mr. Brandstadt. <br /> Also, there were a few locations, including outslopes of the cattle trail just below the reclaimed mine bench and <br /> some ditch locations near the waste disposal site that had not been seeded initially. These areas were pointed <br /> out, and the crew seeded the waste area ditch segments while I was on site. I also discussed the need to <br /> stabilize rills and gullies in several locations on the portal bench and upper reclaimed road (soil fill or packed <br /> 4 <br />