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5 <br />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 />slump, and no remedial action would appear to be necessary. <br />At CRDA-2, refuse was being dumped in the middle third of the <br />active bench, with graded areas at both ends of the bench. Anew <br />bench has been started at the ends of the pile. Some refuse <br />material had eroded from the upper bench outslope into the upper <br />terrace ditch as a result of storm runoff within the last couple of <br />weeks. The gullied refuse slope will need to be graded and <br />accumulations of material in the affected portion of the terrace <br />ditch will need to be cleaned out. The terrace ditch remains <br />functional, and all disturbed drainage appears to have been <br />effectively intercepted by the ditch and conveyed to the sediment <br />pond. <br />The upper diversion ditch at CRDA-2 has not yet been extended as <br />requested in the previous complete inspection report. The operator <br />indicated that this was due to problems in scheduling a contractor <br />to do the dozer work, but that the work would be completed by the <br />end of October. <br />Topsoil <br />At the 2-West Portals site constructed in 1992, topsoil was <br />apparently not separately salvaged, but was removed and stockpiled <br />along with overburden material removed during site development. <br />The permit application does not provide justification for this, and <br />soil textural and chemical analyses included in the application <br />seem to indicate that a relatively good quality topsoil was present <br />on the site prior to disturbance. During the inspection, the <br />operator indicated that a shallow layer of topsoil was present <br />prior to disturbance, but separate salvage of the topsoil was not <br />practicable due to excessive quantity of rock and boulders. High <br />rock content is apparent in the cut slopes and surface soils <br />adjacent to the site. <br />Review of Technical Revision 14 documentation on file at the <br />Division office indicates that the operator had stated in a <br />November 16, 1992, adequacy response letter that they "do not <br />consider any of the disturbance areas [at the 2-West Portals] to <br />have salvageable topsoil..." The operator has been requested to <br />include the justification for not separately salvaging topsoil at <br />the 2-West Portals within the permit application, in the context of <br />the ongoing PR-2 review. <br />