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III. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. Channel "G" had been riprapped, but will require re-work to conform with design channel specifications, incorporating an appropriate mix of smaller sized riprap, proper channel cross-section, etc. Large size riprap currently on-hand will need to be broken up to obtain the desired size gradation; track-hoe rock breaker attachment had not yet been delivered to the site. Additional grading is warranted at the upper end of the channel to ensure that all flow down the undisturbed channel above is captured and funneled into the constructed riprap channel. It was discussed on July 5 that final depth of constructed channels needs to incorporate specified free-board, and that the design specifications the Division will use to assess the construction compliance are listed on the "Ditch Design Summary Master List", permit page M(vii)-1 i. • Subsequent the inspection of June 22, Channel "G" had been further excavated and further extended down slope, as far as could be safely achieved. Large riprap "energy dissipaters" had been set in place at the toe of the channel, and this approach will need to be taken at several of the steep channels that do not fully extend to the native channel at the toe of the slope. All of the permanent channels along the canyon section of the road had been "roughed in" along their lower segments (down-gradient of the backfill bench), with the exception of the lower-most Channel "A", for which excavation had just recently been initiated. Two additional riprap channels will be constructed, based on field conditions which appear to warrant riprap channel installation. The two channels are located between approved Channels "A" and "B", and would be designated "A1"and "A2". Following completion of the grading and channel construction, operator will need to submit a technical revision application with certified "as-built" contours and specifications, addressing any divergences from the approved plan (such as the additional riprap channels, and any changes in channel slope, length, or other design parameters necessitated by field conditions). The "as-built" designs will need to demonstrate compliance with applicable regulatory criteria. Grading work with dozer and track-hoe was continuing along the canyon section of the access road, down the road (west) from Channel "G". West of Channel "G", the top of the compacted backfill bench will be shaped to blend in to the cut slope, to eliminate the "terrace" configuration of the upper-most road segment. Where the cut-slope is not eliminated by the backfill, cut slope crests will be cut back and rounded for blending, to the extent practicable. Similarly, the crest of remnant fill slopes will be rounded off, to eliminate any remaining abrupt slope transitions. Lower Road Areas • Preliminary ripping had been conducted along a section of the lower road. Additional ripping is necessary in the previously ripped sections to provided a properly loosened seedbed along the entire width of the area to be seeded. Ripping will be necessary along the length of the road on BLM property wherever the non-vegetated travel width exceeds 8 feet. • By July 9, the lower road topsoil stockpile area had been properly graded, roughened and bermed; silt fence had not yet been installed. Perimeter livestock fencing yet to be installed. Coal Waste Disposal Area • The waste disposal cell itself had been cover soiled, topsoiled, and extensively roughened. Ditches were in place. The inlet to culvert CMP-2 was partially blocked by loose soil, and needs to be cleaned out. The waste disposal area topsoil and cover soil stockpile areas had also been graded and roughened; final graded portion of the cover soil stockpile area had been topsoiled and roughened. The upper 4