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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 />24-hour storm event. Along the main channel of Munger Creek and its south fork, from upstream of the <br />mine bench area down to its confluence with East Salt Creek, the channel had been severely scoured, <br />and the debris line (high water mark) was high up on the sides of the entrenched channel on upland <br />vegetation such as big sagebrush and juniper. At the 72" haul road culvert on the lower reach of the <br />main stem of Munger Creek, water had backed up, completely filled the deeply entrenched channel <br />upstream of the culvert, and flowed over the road, leaving a wide swath of woody debris scattered along <br />the road and adjacent area. There was minor erosion on the downstream fill slope. It is possible that the <br />culvert had been partially blocked by limbs and debris during the event, but any such debris had been <br />flushed out by the flows, and at the time of the inspection the culvert was intact and clear. <br />When I left the site, the operator was preparing to set up a pump to begin dewatering the coal waste <br />area sediment pond. Discharge will be monitored and reported in compliance with CDPS permit <br />requirements. <br />Remedial measures to be implemented promptly, with no requirement for permitting actions include: <br />Initiate and complete pumping to dewater the pond and provide water storage capacity for the <br />short term. <br />Dig out the 36" CMP inlet and clean out the culvert to restore it to design capacity. <br />Measures to be addressed in a minor revision application to be submitted by August 12, 2005: <br />Estimate quantity of sediment to be removed from the pond, and prepare a plan for clean-out, <br />handling, interim storage (if warranted), and final placement of the pond sediment. Include a map <br />or sketch delineating the designated placement area(s), narrative addressing appropriate site <br />preparation, placement, interim stabilization and long term reclamation measures, and a schedule <br />for initiation and completion of the pond clean-out project (including clean-out/repair of the <br />existing primary spillway pipe). <br />Measures to be addressed in a technical revision application to be submitted by September 6, 2005: <br />Provide an estimate of the storm event magnitude within the Munger/Watershed "F" watersheds, <br />based on available weather records for locations in the general vicinity of the permit area (BLM, <br />NOAA, NWS, State Climatologist, etc.), as well as flow levels in Munger Creek relative to <br />surveyed 50 and 100 year flood level elevations. <br />Provide a plan for clean-out, placement, and stabilization of sediment and rock from the lower <br />segment of the Watershed "F" drainage channel. Include appropriate narrative and amended <br />facility area mapping to define the channel segment to be cleaned out, final profile and <br />dimensions along the affected segment (to approximate original channel dimensions and grade), <br />and stabilization/reclamation measures to be applied to the areas affected by the channel <br />excavation and material placement. Use of material from the channel clean-out to build up a large <br />berm between the drainage channel and the sediment pond is recommended (berm height and <br />dimensions should be specified in the plan). <br />3. Include documentation of correspondence with the Army Corps of Engineers, and any required <br />Army Corps permit approval to allow for the channel excavation project. <br />4 <br />