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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 inspection <br />and the facts or evidence supporting the enforcement action. <br />design specification. This same ditch extends to the north and ultimately into Pond RP-1. The lower, <br />higher gradient section of the ditch has down-cut 6" to 12" along one short steep segment. Along this <br />lower segment, the ditch at the base of the refuse slope is pazalleled by an outer ditch, which wasriprapped. <br />The outer riprap ditch is a stable, "V" shaped channel, approximately 2' deep by 1 S wide. It would appear <br />that the outer ditch is the actual permanent ditch specified in the permit. However, as currently configured, <br />very little drainage is routed to the pond via the riprapped ditch, because any runoff from the vegetated <br />refuse pile is contained within the inner ditch. Operator was advised to divert inner ditch into theriprapped <br />outer ditch, at some point upgradient from the steep segment. <br />East ditch appeared to meet specs along entire length, including upper low gradientvegetated segment and <br />lower high gradient riprapped segment. <br />Combined Refuse Area RP-2/3/4 <br />All perimeter ditches are "temporary in-pit ditches". Final designs are not required to be in place until <br />refuse slopes are covered and seeded, however the interim ditches aze to be maintained to provide design <br />flow capacity and to be stable. Operator has indicated that ditch erosion identified as a concern in the <br />March inspection report in the vicinity of West inlet to Pond RP-4 will be repaired when conditions allow <br />prudent equipment access. The operator has also indicated that measures will be taken to stabilize the <br />series of gullies averaging approximately 2 feet deep, along the boundary between the toe of the refuse and <br />the inslope of Sediment Pond RP-4. <br />The following additional observations were made during this inspection. <br />• Downcutting has occurred along the lower segment of the East Perimeter ditch, above the upper-most <br />rock check, within a section of channel previously lined with river cobble. Stabilization is warranted. <br />• On the West Perimeter Ditch, maintenance is needed along a short segment of low gradient ditch <br />approximately 300 feet west of the Pond4 west inlet, where coaly sediment has accumulated. <br />• The lower end of the steep riprapped segment of the West Perimeter Ditch has down-cut 1 to 2 fee[ <br />deep, and angular riprap needs to be installed within this segmeut, to extend theriprap section to the <br />ditch comer, where gradient is significantly reduced. <br />• A section of West Ditch just below the dozer crossing road (designated Segment 3 in Illus. 44) needs <br />maintenance for sediment cleanout. Measured cross section was 15" d, with 8'tw. Design <br />specif cation is 24" d, with 8' tw. Operator pointed out that if flow escaped the ditch in this location, it <br />would re-enter the ditch a short distance below, which did appear to be the case. Regardless, ditch <br />needs to be maintained to provide design capacity. <br />• Straw bale check dams installed at various locations along the interim in-pit ditches have proven for <br />the most part to be ineffective, and have resulted in channel side-cutting at several locations. Straw <br />checks where channel sidecutting has occurred should be dismantled, and use of straw bale checks <br />within the perimeter ditches should be discontinued. <br />