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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 />benches based on characteristics of the processed waste, which they indicate dictate the need for large work <br />areas, and multiple sub-areas open at one time. Page IV-4 of the P.A.P. states "Experience with the refuse <br />has shown that more than one sub-area must be used at a time to allow drying of the refuse prior to <br />compacting in lifts. Drying becomes a pazticulazly difficult problem during the winter months. It is <br />anticipated that about 120 acres may be in use at any one time." <br />RP-SA <br />At RP-SA, permanent 100 year perimeter collection ditches with fmalriprap installation, or vegetated <br />sections with rock checks, were installed when the pile area was initially disturbed. For the most part, these <br />ditches are located topographically above the current refuse pile elevation, and so very little if any <br />disturbed flow is routed through the ditches, which are consequently in very good condition. At some point <br />in the future, the refuse pile will attain elevations such that disturbed drainage from pileoutslopes will <br />drain into the permanent ditches. At present however, disturbed drainage from the refuse area is contained <br />by the natural topography and excavation associated with refuse area development. Drainage flow is <br />generally to the north (towazd the sediment pond) and gullies up to 4 feet deep have developed in the <br />vicinity of the pond inlet area. The gullying extends back towazd the toe of the compacted refuse for <br />approximately 100', across disturbed ground from which topsoil and subsoil have been removed. <br />Measures need to be taken to repair/stabilize the eroded areas pursuant to Permit Section IV.D.3, <br />and Rules 4.09.2(7) and 4.10.3(3). <br />Pond SA was iced over at the time of the inspection, approximately 6 feet below the level of the open <br />channel primary spillway. Pond SA has never discharged. Page IV-39 of the permit states that "in order to <br />maintain a 10-year storage volume after a major storm event, the water level in Pond RP-5 will be <br />dewatered at least ].65 feet below the primary spillway." Dewatering would presumably be by pumping. <br />Pond Design Map 80A depicts a two level open channel spillway, with a 15 wide emergency spillway <br />channel located 1.4 feet above the immediately adjacent 10' wide primary spillway channel. The 1.4' <br />separation was not appazent from visual assessment Modification of the channels and/or modification <br />of ezisting riprap placement is warranted to better define the two level spillway to conform with the <br />design detail specified on Map 80A. <br />Combined Refuse Area 2-3&4 <br />At the combined refuse area, fma] permanent diversions werenot constructed prior to initiation of refuse <br />disposal activity. Refuse pile runoff is directed into the sediment ponds via "interim perimeter ditches" <br />constructed along the toe of the refuse. In a couple areas, unsightly gully erosion has developed in the <br />immediate vicinity of the refuse area sedimentation ponds. The fnst area is at the west inlet to Pond RP-4, <br />where the interim ditch has downcut severely, resulting in a gully approximately 5 to 6 feet deep extending <br />for approximately 60 feet. <br />A second area of concern is along the southern perimeter of RP-4, where a series of closely spaced parallel <br />gullies averaging 2 to 4 feet deep have developed along a 40 foot wide corridor between the toe of the <br />