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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 /> (p)The slide feature noted in the aerial inspection is marked for repair on the 2008 Rill and Gully Survey Map, <br /> and is depicted on the GPS map as GPS#29, Photo 3973. It is located in the"East Wadge Area", which has not <br /> been approved for Phase 1 bond release and is not within the SL-3 bond release request area. <br /> (2)Surface and ground water monitoring data, and whether pollution of surface or subsurface water is <br /> occurring, the probability of such future pollution and the estimated cost to abate pollution— <br /> No evident water quality problems were noted during the SL-3 inspection, nor were any such problems noted <br /> during the SL-1 inspection or subsequent inspections, with respect to the SL-3 bond release area. The three <br /> sediment ponds within the bond release area (Pecoco, 004, and 008) have been approved as permanent <br /> impoundments, and were discharging clear flows at the time of the inspection. Pond embankments were stable <br /> and well vegetated. The large Wadge impoundment(Sediment Pond 002) is not within the SL-3 release request <br /> area, but receives discharge from the Pecoco Pond and disturbed runoff from areas downstream of Pecoco, <br /> within the SL-3 area. Pond 002 has also been approved as a permanent impoundment and was discharging <br /> clear flow at the time of the inspection. SCC has submitted water quality monitoring summary data within the <br /> narrative and Attachment F of the SL-3 application. This information and additional relevant information from the <br /> operator's extensive surface and ground water quality monitoring program will be reviewed by the Division during <br /> the course of the SL-3 evaluation, to ensure that the operation's impacts to water quality are within the bounds <br /> projected in the approved Probable Hydrologic Consequences (PHC)assessment, and that material damage to <br /> water quality is not occurring or anticipated. <br /> (3)Stability of reclaimed surface lands— <br /> Erosional and mass stability of reclaimed slopes and permanent drainages was a major focus of the 2006 SL-1, <br /> Phase 1 bond release inspection, and only a relative few, isolated areas of concern within the SL-3 release <br /> request area were identified in that inspection. Despite the fact that 2007/2008 snowpack and resultant runoff in <br /> the mine vicinity was unusually heavy, the extent of excessive erosion and slope failure features within the <br /> release request area remains very minimal. Generally, past grading and channel construction operations, in <br /> combination with good to excellent vegetative ground cover establishment and annual rill and gully monitoring <br /> and repair activities have resulted in a stable reclaimed landscape. Remnant minor scarps and cracks from <br /> healed or repaired slump features are evident in various steep slope locations, but with exceptions noted, the old <br /> slump areas appear to have stabilized and have not moved in many years. A few areas of minor gully erosion, <br /> ditch scour, and one small slump were observed within the bond release application area, and stabilization <br /> grading or other maintenance will be necessary. The slump and several of the gullies were delineated by the <br /> operator on the 2008 Rill and Gully Survey Map; however some of the gullies and segments of scoured road <br /> ditches had not been identified on the Rill and Gully Survey Map. The slump and erosional areas that warrant <br /> repair are listed below. These features will need to be properly repaired during the 2008 field season, <br /> prior to issuance of the Division's proposed decision on SL-3. <br /> • Steep segment of ditch along the road between Pond 004 and Pond 008 has eroded, and repair <br /> is warranted, Photo 3975, and GPS Feature#39, noted previously under"Past Inspections"section of <br /> this report. <br /> Minor channel erosion is evident along a segment of PM-6 above Stock Pond T-32, upstream of the <br /> riprapped section (see Photo 3978/GPS Feature#13). Stabilization is warranted, and the segment <br /> is marked for repair on the 2008 Rill and Gully Survey Repair Map. Noted previously under"Past <br /> Inspections"section of this report. <br /> 7 <br />