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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 <br />inspection and the facts or evidence supporting the enforcement action. <br />• As noted previously, several of the steep channels do not fully extend to the native channel at the toe of <br />the slope. The channels were extended as far down the slopes as equipment could safely reach, and <br />generally beyond the lowest elevation specified in the approved plan. These locations will need to be <br />monitored following future heavy runoff events. Some erosion may occur below the outlets; if <br />the constructed channels are compromised, repairs will be warranted. <br />Two additional riprap channels had been constructed that are not specified in the approved design (as <br />referenced in the previous inspection report. The two channels are located between approved Channels <br />"A" and "B", and would be designated "A1" and "A2". The operator has been requested to submit a <br />technical revision application with certified "as-built" contours and specifications, addressing any <br />divergences from the approved plan (such as the additional riprap channels, and any changes in <br />channel slope, length, or other design parameters necessitated by field conditions). The "as-built" <br />designs will need to demonstrate compliance with applicable regulatory criteria. <br />• In a couple locations, there is remnant "elephant trunk" culvert outlet fabric remaining on the slopes that <br />will need to be picked up and hauled out by the operator. In one location there are segments of <br />fiberglass tubing that will also need to be removed and properly disposed of. <br />• A couple non-riprapped channels not specified in the plan were installed where minor ephemeral <br />drainages had crossed the road. Along one of these channels, the contractor had installed water bars. <br />The water bars need to be graded out for form a uniform channel bottom. The channel also <br />needs to be graded out at the lower end to tie in better to the slope below, and eliminate the <br />abrupt transition. <br />Lower Road Areas and Waste Disposal Area <br />Additional ripping had been completed along the lower segment of the road, which will remain in place, <br />with an 8 foot travel width. Ripping is warranted along certain segments; the 8 foot travel width had <br />been marked out, and ripping was in progress when the inspection was completed. <br />Perimeter livestock fencing of areas specified in the plan has not yet been initiated, but will commence <br />shortly. <br />• The road ditch along the north side of the road in the vicinity of the waste disposal area topsoil stockpile <br />and a short distance further to the east needs to be graded to restore approved design and direct road <br />drainage from this segment to the sediment pond. <br />The roughened waste disposal area, topsoil pile area, cover soil area, and lower topsoil stockpile area <br />had all been seeded with cover crop since the previous inspection. The inlet to culvert CMP-2 had been <br />cleaned out as requested. <br />• Power poles removed from the canyon had been piled near the lower stockpile area, and will need to be <br />removed and disposed of. <br />4 <br />