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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 /> the currently approved plan. SCC is negotiating with the BLM for retention of a light use <br /> segment that connects permanent road LU3B in the South Pit area with permanent road LU3A in <br /> the neck pit area,but currently this segment is not approved as permanent. There is an active use <br /> scraper road (not depicted as a road on the SL-2 maps) that extends from the temporary road <br /> along YPM 6-2 up to Stockpile"U. The scraper road will be subject to continued use during <br /> topsoil haulage associated with reclamation of the Pond 012 slide and adjacent areas, and will <br /> need to be regraded/eliminated when it is no longer needed, to prevent concentration of runoff <br /> along the route. The scraper route was improperly included within the SL-2 release request <br /> area. <br /> In the North Pit Area, a light use road previously extended from the permanent neck pit road <br /> (LU3A), across Armand Draw, then up along YPM-10 and over the divide down along YPM-9 to <br /> Pond 1 IA. This road was previously noted by the Division as being improperly included in the <br /> (SL-1)bond release area. The Division excluded the entire length and width of the road <br /> disturbance from the SL-1 approval in 2007. Subsequently, all but the western end (550') of the <br /> road was reclaimed (eliminated) and the reclaimed corridor was included in SL-2. The western <br /> end is designated LU2, and was not requested for Phase 1 release in SL-2. The segment of <br /> reclaimed road west of the Armand Draw/Grassy Creek divide (Pond 010 watershed) was <br /> checked during the SL-2 inspection; the road had been properly regraded, topsoiled, and <br /> revegetated and appeared stable (Photo MLT716427). Areas east of the Armand Draw/Grassy <br /> Creek divide, in the Pond 011 A watershed, were not inspected during the SL-2 inspection. <br /> Significant erosion had been noted within the Pond 011 A watershed during the Division's June <br /> inspection, and the operator indicated repairs had not been completed at the time of the SL-2 <br /> inspection. The Division plans to inspect the Pond 11 watershed during the October 2009 <br /> inspection, prior to issuance of a proposed decision for SL-2. <br /> The reclaimed Haul Road "D" corridor extends from near the south end of Shrub Plot SP07-1 in <br /> the Neck Pit vicinity, for approximately 3500 feet to the southwest, ending on the ridge north of <br /> Sediment Pond 012. The corridor was not inspected in July due to time constraints,but the entire <br /> length of the corridor was walked during a follow-up inspection on August 12, 2009. No <br /> problems were noted with respect to backfill and grading of the Haul Road"D" corridor within <br /> the SL-2 request area. Reclaimed slopes blended well with adjacent topography, small <br /> ephemeral drainage crossings were stable with vegetation becoming established through turf <br /> reinforcement mat(TRM) liner, and the few hillslope rills observed were healing in with <br /> vegetation. One old settling feature approximately 40' in diameter was observed on a steep slope <br /> at the east end of the corridor. The slope appeared to have stabilized; perimeter cracks have <br /> largely filled in with soil and the remnant scarp is no higher than 6 inches. <br /> 3 <br />