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properly reclaimed with the exception of a short reach at the lower (northwest) end, which has been <br />approved as Light Use Road LU -2. Channels PM -10, PM -21, PM -21A, and PM -21B were observed to <br />be stable and in conformance with approved designs. One gully that will require maintenance extended <br />up -slope and to the south from the upper end of PM -10. The gully is considered a maintenance item to <br />be stabilized by the operator in accordance with the Rill and Gully Plan of the approved permit. All of <br />the exclusion areas under SL -1 will be proposed for Phase I bond release approval under SL -2, with <br />exception of the entire length of Channel PM -13 as described below. <br />In the Grassy Creek watershed portion of the North Pit area, heavy rains earlier in the year had resulted <br />in significant erosion along PM -13, and slope areas that drain into both PM -13 and PM -9. Detailed <br />observations are included in the Division's follow -up bond release inspection conducted on 10/13/09. <br />Erosion repairs had been implemented in the watershed prior to the 10/13 inspection, but were not yet <br />complete. Gullies had been graded out and fully repaired in some locations. Minor riprap repairs were <br />warranted along the upper section of PM -13, where underliner material had been exposed. Given the <br />continued erosional instability of the watershed, including areas tributary to Channel PM -13, and the <br />maintenance warranted along the upper end of PM -13, the Division will exclude the entire length of <br />PM -13 from SL -2 approval. The excluded corridor along PM -13 is 1.8 acres and is delineated on Figure <br />3a - Phase I Bond Release Proposed Approval Areas. Figures 3a and 3b show the SL -2 Phase I <br />proposed approval and exclusion areas for the north and south portions of the mine site, respectively. <br />Photograph No. 2 shows the erosion that is occurring at the head of the PM -13 channel. <br />Although the Division noted in the October 2009 inspection report that exclusion of Channel PM -9 <br />from SL -2 approval might be warranted, it was subsequently determined that Phase 1 release had been <br />granted for PM -9 in SL -1. Although there was heavy runoff and resultant erosion in the PM -9 <br />watershed during 2009, the channel itself remained stable. <br />South Pit Area <br />The largest acreage requested for release within SL -2 is in the South Pit area. For the purposes of SL- <br />2, the South Pit area includes all disturbed lands located to the south of the Section 18/19 and Section <br />17/20 boundary lines, within the permit area. Reclaimed watersheds within the South Pit area drain <br />to one of three sedimentation ponds; Pond 012, Pond 013, or Pond 014. The Pond 012 watershed is <br />the largest, Pond 013 watershed is the smallest. Each of the major pond watersheds contains several <br />sub - watersheds, with their associated permanent channel network. <br />Backfill and grading, in the South Pit Area was initiated in 2000 and was completed in 2007 for all areas <br />included in the SL -2 Phase I bond release. Exhibit B of the bond release application package provides <br />detailed information on the chronology of backfill and grading work in the South Pit. There was no <br />backfill and grading work completed in 2001 or 2002 and the majority was completed in 2005 through <br />2006. Photograph No.'s 3 and 4 show views of the South Pit from the southeast end of the <br />disturbance area looking north before and after reclamation, respectively. Photograph No. 3 was <br />taken in 2005 during active mining. Photograph No. 4 shows the South Pit area following backfill <br />and grading, drainage reestablishment, and revegetation and demonstrates that the site was returned to <br />the approximate original contour. Areas not included in the release request include all sediment <br />ponds and stock tanks, permanent roads, certain light use roads in the South Pit and Neck Pit vicinity <br />11 <br />