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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 /> Slides and Damage <br /> Two areas affected by significant landslides in the past have been held out of the area that the Division is <br /> proposing to approve within Phase I bond release SL-2. One of these slide areas is the slide complex in the <br /> lower 016/016A drainage of the South Extension area, described previously in the Hydrologic Balance section of <br /> this report. As noted, there has been additional movement this spring on the in-slope to Pond 016A. As further <br /> noted, a remediation plan based on geotechnical and hydrologic evaluation of the slide complex is being <br /> prepared by SCC, and a complete technical revision application addressing remediation of the slide <br /> complex will need to be submitted no later than July 15, 2010. This extension (from March 31, 2010) is to <br /> allow sufficient time for field survey and assessment as warranted to incorporate the new slide on the Pond 016A <br /> in-slope into the remediation plan. <br /> The second slide feature that was held out of the SL-2 proposed approval area is located on the reclaimed "A" <br /> Pit highwall slope, on the NW facing slope southwest of the upper 006 Channel segment. The slope had failed <br /> several years ago and was regraded to a lesser(approximate 30%)slope, by reducing the slope crest elevation. <br /> Parallel cracks and bulging subsequently developed due to renewed slope movement, and the area was again <br /> regraded in the fall of 2009. Cracks and bulging have reappeared this spring, in the same approximate location <br /> on the slope. The primary crack is located approximately midway down the slope, is approximately 125 yards <br /> long, with up to approximately 1' of displacement evident. A smaller crack and bulging is evident approximately <br /> 30 to 50 feet below, and roughly parallel to the upper crack. Assessment of the factors resulting in the continued <br /> instability of the slope will be warranted during 2010. SCC will need to assess the factors resulting in the <br /> continued instability of the slope and present a conceptual remedial plan within an addendum to the <br /> 2010 Rill and Gully Plan, no later than July 15, 2010. The slope grading performed last fall was completed in <br /> November. Due to significant snowfall as the topsoil spreading was being completed, only the upper half of the <br /> slope was seeded in the fall, and slope roughening was not implemented, with the exception of minor <br /> roughening from dozer cleat marks. The cover crop seeded in fall along the upper slope had only very recently <br /> germinated, and the lower slope was seeded only within the last couple weeks as the snow was melting off. <br /> Shallow rills had formed along the lower portion of the slope from snowmelt. SCC will need to take <br /> appropriate measures as necessary to provide for soil protection and prevent gully erosion on the <br /> slope. Given the fact that the slope has been seeded, application of certified noxious weed-free straw <br /> mulch,Woodstraw or equivalent,wood fiber hydromulch, or rolled erosion control products would be <br /> appropriate options. <br /> The area of the eastern ridgeline in the former neck pit area of the South Extension has been subject to <br /> landslides and repair work in the past, specifically the corridor along the Ridgeline light use road (LU4), between <br /> culvert PM-12 and PM-10. The slide repair slopes showed no evidence of renewed movement, and remedial <br /> diversion and drainage structures including the PM-4D TRM channel and temporary flex pipe appear to have <br /> functioned well and remain in good condition. Remnant snow drifts were still present adjacent to the road at the <br /> crest of the primary slide repair zone, at the upper end of PM-4D. <br /> An area was checked where minor cracks and slumps were repaired in the early summer of 2009 on the south <br /> facing reclaimed highwall slope to the north of the lower end of Channel 005-E1, in the former"D" Pit area. <br /> Repairs have held up, with no renewed cracking or slumping. However renewed cracking was observed in the <br /> vicinity of a seep location on the slope to the south of the point where 005 Gulch enters Stock Pond T-18. A <br /> crack in this location had been graded over in the summer of 2009, but has re-opened. At this time, the crack is <br /> narrow, approximately an inch wide, and forms a semi-circle approximately 150'wide. Soils in the immediate <br /> vicinity were saturated, possibly due both to snowmelt and groundwater seeps. This area will need to be <br /> assessed over the course of the growing season to determine if remedial measures are warranted. <br /> 7 <br />