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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. steeper in the extreme northeast corner of the reclaimed area. Gradient depicted on Exhibit 8C in the northeast comer is approximately 25%, which appears [o correspond closely to the existing topography. Due to time constraints, additional reclaim slope transects were no[ run. Based on visual observation, the western portion of the reclamation area is characterized by short, relatively steep upper slope segments (e.g 30 feet in length and up to 20% to 25% gradient) and long, low gradient (approximately 5% or less) lower slopes. This topography appears in general to correspond to the topography depicted on Exhibit SC. One issue of potential concern discussed with the operator is that several erosional drainage chutes occur on the steep hillslope above the reclaimed slopes. Intense storm events result in concentrated flow in the chutes, which is intercepted by the upland ditch and diverted around the disturbed area. Upon removal of the upper diversion (anticipated in several years, after the reclaimed site is stabilized by vegetation), it would appear that the relatively steep, unconsolidated upper reclaimed slope segmenu would be subject to gully erosion due to concentrated flows from the drainage chutes. Provision for construction of stable drainages across the reclaimed area prior to removal of the upper diversion maybe warranted. The Division will evaluate [his issue during the current permit renewal review. Processine Waste RSRDA Minor erosion was evident at the location where the main upland drainage above the refuse pile ties into the riprapped upper perimeter ditch. Stabilization measures are warranted to prevent further erosion. An erosional feature has developed on the 2°d level bench outslope, near the north end of the refuse pile. There is a gully approximately 12 -18 deep, approximately 15 feet in length which begins abruptly on the slope and terminates at a bench terrace drain below. The cause of the gully is not readily appazent, but it appears to be associated with piping erosion beneath the replaced cover soil. The nature and cause of this erosion should be described in the 3rd quarter refuse pile inspection/certification report, and appropriate corrective measures should be described in the report and should be imp-emented prior to final seedbed preparation work. t.1ZDA-1 and CRDA-2 There appeazed to have been less rain on the CRDA refuse areas than in the South Portal vicinity. Some maintenance grading work as requested in the previous inspection report still needs to be conducted on CRDA-2, to establish better grade on a segment of Terrace Drain #2 and a segment of Terrace Drain #4 (refer to August 7, 2002 inspection report for detail). Support Facilities Tonya Hammond indicated that remaining metal debris at the South Portal area was scheduled to be removed by the end of September. Substation B demolition is also scheduled [o be completed by the end of the month.