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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 d~iring the inspection <br />and the facts or evidence supporting the enforcement action. <br />monitoring prior to 1997, refer to the DMG inspection report of 8/29/97 (page 2) and <br />addendum of 10/17/97 (page 1). Since that time, restrictions have been reported for #107 <br />three times (4'" qtr. '98, 4`" qtr. 2000, 4`" qtr. 2002), for #303 one time (4`" qtr. '98), and <br />for #307 6 times (4`" qtr. '98, all four quarters of 2000, 2ntl qtr. 2001). In the Division's <br />judgement, these occasional monitoring problems with three of the 30 piezometers do not <br />represent a significant flaw in the monitoring program. Monitoring of the problem <br />piezometers has been successful on many occasions and has not indicated a single <br />exceedance. Further, uniformly successful monitoring of the remaining assemblage of 27 <br />piezometers has never indicated an exceedance. Given these facts, and because of the <br />absence of features indicative of slope instability, the Division has not and is not at this <br />time requesting replacement of any of the occasionally problematic piezometers. <br />Several maintenance items were noted during the inspection. <br />CRDA-1 Maintenance Items <br />1) There was shallow puddling on Terrace Drain #3, in the immediate vicinity of the sharp <br />curve in the terrace drain, at the southeast corner of the pile. Maintenance is needed to <br />establish postive grade toward the southeast perimeter ditch. <br />2) Channel erosion has developed along a lower segment of the NW collection ditch, <br />extending from the toe of the steep riprap segment at the north end of the pile, around the <br />sharp curve in the ditch adjacent to Haul Road 4. A gully up to a foot or more in depth <br />extends for approximately 50 to 60 feet down gradient from the corner of the ditch. <br />Extension of riprap placement along the length of this segment would appear to be <br />warranted. <br />RSRDA <br />The Roadside Refuse Disposal Area (RSRDA) has not been actively used for refuse disposal <br />since 1981. Upon cessation of disposal at the site, the outstopes of the pile were graded, <br />and subsequently covered with a 6 inch soil thickness and reseeded. Soil thickness <br />revegetation test plots were installed on various locations of the pile, and data from the test <br />plots provided the basis for required refuse soil cover thickness on CRDA-1, CRDA-2, and <br />final reclamation of the RSRDA. The flat top of the pile was approved for use as a supply <br />storage yard. <br />In 2002, extensive final reclamation work was performed on the pile. The initial reclamation <br />project included installation of two terrace drains and final grading of the pile outstopes, and <br />placement of permanent soil cover, which was completed in the late spring. Final <br />reclamation of the cover soiled slopes, including extensive roughening, seeding, mulching, <br />and rock distribution was completed in November 2002. In addition, a new permanent <br />upland diversion was constructed to route upland runoff around the top and to the south of <br />the pile, into Sediment Pond 9. Also, a new North Perimeter collection ditch was <br />constructed along the north side of the pile to direct drainage from the terrace drains into <br />Sediment Pond 8. Minor grading was completed on the top of the pile to direct runoff away <br />10 <br />