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111. 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 <br />inspection and the facts or evidence supporting the enforcement action. <br />SEDIMENTATION PONDS <br />There was no water in pond B, although there was some mud at the very bottom of the pond. <br />There was no water in pond C, and no evidence of any water ever having been in the pond. All <br />spillways were functional and embankments appeared to be stable at this time. The riprap in the <br />emergency spillway outslopes was in place and appeazed to be stable. However, numerous <br />desiccation cracks were noted in the portion of the pond C embankment top that lies between the <br />emergency spillway and the concrete abutment. The desiccation cracks may be caused by a too- <br />high clay content in the pond embankment. The Division will be requesting, in a letter, to either <br />demonstrate the stability or to reduce the clay content material of that portion of the pond C <br />embankment. The gob pile pond has not been built yet. <br />Various aspects of sedimentation ponds B and C were reviewed, in order to evaluate the <br />operator's pond as-built statements that the ponds were built according to the approved designs, <br />The dimensions of the emergency spillway, the primary spillway diameter, and the elevations of <br />the primary spillway, emergency spillway, pond bottom and pond embankment top were also <br />measured. General pond geometry and locations of specific structures associated with the pond <br />were also examined. The various measurements were made with a five foot measuring stick, an <br />abney level and a tape measure. Therefore, these measurements were only approximate. <br />The as-built construction for pond B generally agrees with the design specifications for that <br />pond, as shown on Map No. 22-B of the permit application. "fhe pond embankment outslopes <br />and inslopes did not conform exactly to the design slopes of 3H:1 V and 2IF:1 V. Part of this <br />discrepancy may be because of the accuracy of the measuring equipment. [n some cases, <br />however, the outslope did seem a little steeper than 3H:1 V, due to the steeper natural undisturbed <br />slopes that the pond embankment ties into. However, the pond embankment width was at least 13 <br />feet, with the average width approaching 15 to 20 feet. This large width makes up for the slightly <br />steeper slopes in some azeas. The pond elevations and the dimensions of the emergency spillway <br />and primary spillway check out with the as-built, although the pond embankment top elevation is <br />a little higher than the design shows, in some places. <br />Generally speaking, the constructed pond C conforms to the design specifications, as shown on <br />Map No. 22-C of the permit application. Some of the inslopes aze a little steeper than 2H: l V, but <br />not by much. The outslopes conform with the design specifications, except fora 40 to 60 foot <br />long section just west of the emergency spillway. That section of the outslope is too steep and <br />