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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 <br />inspection and the facts or evidence supporting the enforcement action. <br />RP-4 <br />Refuse was being hauled to this pile during the inspection. <br />This pile also has a collection ditch at either side, neither of which has been rip rapped or <br />seeded as called for in the design. There is an interim in-pit ditch on the east side of the <br />pile, so the east collection ditch is not currently used. The m-pit ditch had been eroding, <br />and so had been armored with river rock at the bottom 50-75'. The east collection ditch <br />runs on the pond access road for the last 100', where it becomes wide and shallow. The <br />operator indicated that because the pile was not yet at final elevation, the design <br />location/elevation of the lower end of the ditch could not be realized. It was suggested to <br />the operator that for the last 100' or so, the ditches could be combined, with the final ditch <br />being directed onto the bottom segment of the interim ditch. The operator agreed with this <br />approach, and will implement the plan immediately. Design details and tmung will be <br />spec~5ed m TR 39. <br />The west side collection ditch, like the RP-SA ditches, has not yet been put into use or <br />coin letely constructed. For the same reasons outlined above, the west ditch should be <br />seeded and armored this Fall. <br />RP-2 3 <br />This pile was not active at the time of the inspection. It had recently been regraded and <br />compacted, in an effort to reduce the sediment m runoff from the pile. <br />The west collection ditch of this pile has not been vegetated or armored, as the pile remains <br />under construction. The ditch has been temporarily stabilized with straw bales. Since the <br />refuse area is reworked on a regular basis, temporary stabilization is acceptable and <br />necessary. The operator should, however, be sure to maintain the ditch such that it is <br />always large enough to convey runoff from a 100-year, 24-hour precipitation event. <br />The lower end of the east collection ditch had been lined with river rock. The remainder <br />of the ditch was temporarily stabilized by straw bales, approximately every 50'. Division <br />personnel expressed their concerns with stabilization by straw bales, m that they are not <br />effective when used as energy dissipators of high velocity flows. The Division suggested a <br />number of alternatives, including check dams, np rap with protective lining underneath, and <br />dugout sediment traps. It was also suggested that runoff and sediment into the collection <br />ditch could be lessened through the use of contour ditches on the refuse pile, which would <br />break up long stretches of flow on the pile. The operator decided to try contour ditches and <br />dugout sediment traps, in combination, initially. If this does not prove effective in stabilizing <br />the ditch, other methods may be employed. The operator will, with pending TR 39, request <br />approval of a number of sediment control methods which may be used singly or m <br />combination. Construction of the contour ditches and traps should be immediately after <br />approval. <br />Deserado Mine 2 May 3, 1996 <br />