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O <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 />ditch scouring in some of the "in pit" collection ditches. TR-39 <br />which is currently under review will address various secondary <br />sediment control measures and ditch stabilization techniques which <br />should reduce erosion and minimize the amount of sediment delivered <br />to the sediment pond. Measures to be employed include <br />scarification of graded refuse slopes, and use of sediment traps, <br />rock check dams, riprap, and reseeding of certain ditch segments <br />and adjacent disturbed areas. <br />The approved reclamation plan allows for "more than two refuse <br />subareas" to be open at any one time, with a maximum of "about 120 <br />acres" to be in use at any one time, to ensure that sufficient area <br />is available to allow for spreading and drying of refuse as <br />necessary to achieve proper compaction. Currently, three refuse <br />subareas are in use, with a total disturbance acreage of <br />approximately 121 acres. One apparent discrepancy is that the <br />approved reclamation schedule, as set forth on Map 76, indicates <br />that RA-2/3 and RA-4 would be reclaimed in 1996. For various <br />reasons, refuse quantities produced have been significantly lower <br />than originally projected, and neither area has reached capacity. <br />An anticipated future revision to combine the two areas and add <br />additional capacity would further extend their operational life. <br />The operator has recently modified the Map 76 reclamation schedule, <br />as a part of TR-39, to indicate that RA-2/3 and RA-4 would remain <br />active until 2004. As stated previously, TR-39 is currently under <br />review. <br />An additional reclamation plan discrepancy is that there appear to <br />be two different final reclamation contour maps for RA-2/3 and RA- <br />4. This issue is being resolved as a part of TR-39. <br />The 1995 Annual Reclamation Report was checked during the <br />inspection, and it was noted that information required by Rule <br />2.04.13(1)(f) pertaining to cumulative listing of revegetated areas <br />had not yet been provided. This information was previously <br />requested in a January 30, 1996 letter from Dan Mathews to Murari <br />Shrestha, and should be submitted as soon as possible. <br />During the permit review conducted in preparation for the <br />inspection, it was noted that, on Page IV-56 of the permit <br />application, the narrative references the possibility that refuse <br />disposal activities might disrupt antelope passage between habitat <br />to the north of the disposal, and a permanent water source at <br />Cactus Reservoir to the southeast. The narrative states that "the <br />