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III. COMMENTS-COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made during the <br /> inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br /> evidence supporting the enforcement action. <br /> It was also agreed that the collection channel that leads into pond 5 from the north needs to be retained. The <br /> channel serves as part of the drainage system to direct runoff around the covered coal waste fill area. The channel <br /> is wide and well vegetated and would blend into the reclaimed pond 5 drainage. However,the 18 inch diameter <br /> black corrugated plastic culvert that lies on the surface and brings runoff from the upper bench down to the pond <br /> 5 collection channel will need to be removed. There are three white plastic pipe underdrains that project out from <br /> the base of the reclaimed mine slope. It was agreed that the pipes should be cut back to ground level and the pipe <br /> outlets covered with rock. <br /> The reclaimed mine benches appeared to be stable. There were no signs of slope instability or erosional gullies on <br /> the reclaimed slopes and terraces. There were no signs of a highwall remnant at the top of the reclaimed area. The <br /> reclaimed slopes and terraces were well vegetated. Although thistle had been recently sprayed,there were still <br /> scattered occurrences of the noxious weed, as well as houndstongue and curly doc, which the operator must <br /> continue to control. The drainage channel on the top reclaimed mine bench needs to be kept in place to keep <br /> water off of the covered coal waste fill. There was a remnant of an upland diversion ditch in the northeast corner <br /> of the site. It was agreed that this ditch should not be reclaimed since the ditch is small in size and that the work <br /> to reclaim it would produce further surface disturbance. <br /> There were several piezometers and survey stakes housed in plastic pipes on the reclaimed benches. The <br /> piezometers will be reclaimed by removing the plastic pipes, filling the holes with bentonite and covering the <br /> immediate area with soil. The survey stakes are roof bolts secured in concrete. For reclamation,the plastic pipes <br /> will be removed,the roof bolts will be cut below the ground, and the holes filled in with soil. Surface disturbance <br /> markers were up around the disturbed area and will be removed upon approval of final reclamation. The <br /> reclaimed haul road had a good vegetative cover and appeared to be stable. <br /> The inspection continued to the west side of Hubbard Creek across from the mine entrance gate where the <br /> reclaimed temporary coal stockpile area and pond 4 are located. Pond 4 was dry. The pond inslopes and outslopes <br /> were well vegetated and the pond discharge structures were functional. As mentioned previously for pond 5, <br /> pond 4 will be reclaimed after the soil loss comparison demonstration is approved by the Division in a minor <br /> revision to be submitted by the operator. As also mentioned previously, final bond release can not be made until <br /> an appropriate vegetative cover is established on the backfilled and graded pond 4. It was agreed that, after the <br /> pond discharge pipes are moved, only the northeast section of the pond 4 embankment will be pushed back into <br /> the pond for reclamation. The remaining pond embankment was well covered in vegetation and would be better <br /> left undisturbed. There was an infestation of knapweed adjacent to pond 4. The knapweed needs to be sprayed <br /> before backfilling of pond 4 begins. <br /> The nearly flat and reclaimed temporary coal stockpile area that drains to pond 4, by way of a culvert under <br /> Hubbard Creek road, was well vegetated. The road culvert does not need to be reclaimed since it provides <br /> additional drainage for the immediate area. The upland diversion ditch was also well vegetated. It was proposed <br /> that the ditch remain since reclaiming it would only increase the surface disturbance and allow for noxious weed <br /> infestation.No erosional problems were observed at this site. However,there were additional occurrences of <br /> knapweed in the central portion of this area that must be sprayed and controlled. <br /> c:/word/blueribbon/insp0808bond <br /> Page 5 <br />