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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 d~lring the inspection and the facts or evidence supporting the enforcement action. from the outslope, but final grading and reclamation of the top of the pile has not been performed and is not required until 2004. - Adequate soil cover thickness (18 inches) on the reclaimed slopes was documented in a DMG inspection report of January 31, 2003. Construction certification for the new upper diversion ditch is included in the 3rd quarter 2002 refuse area P.E. certification by Jim Stover. DMG measurements of the new upper diversion ditch are documented in the January 31, 2003 inspection report, The P.E. certification identified certain discrepancies between the ditch design and the "as-built" configuration, but included documentation confirming the adequacy of the as-built ditches. DMG measurements were consistent with Mr. Stover's certification, and the Division concurs that the Ditch as constructed will safely convey the design flow. The new North Perimeter Collection Ditch has apparently not yet been certified. Some uncertainty exists concerning the applicable design for this ditch. On the currently approved version of Exhibit 6C, the north perimeter ditch, which receives runoff from the terrace drains and will ultimately receive drainage from the french drains to be installed during future reclamation of the portal bench, is designated as "Ditch Segment F". This corresponds to text on approved permit page 14-8, which indicates that Pond 8 would receive interim runoff from ditch segment F, among others. However in contrast, proposed Exhibit C included in TR-42 depicts a North Collection Ditch receiving flow from the terrace drains, that is separate from Ditch Segment F. In this version of Exhibit C, the North Collection Ditch and adjacent Ditch Segment F both feed into Ditch Segment G, near the northwest toe of the refuse pile. The permit does not appear to contain designs for the RSRDA North Collection Ditch. Bench outslopes appear generally to be in compliance with design gradient and bench heights, however there is one apparent discrepancy concerning terrace drain width. Text on permit page 14-6 states that "final contours for the RSRDA include 2-2.5h;ty slopes between 10' and 15' wide benches on 30 to 40 foot elevation intervals..." The terrace drain width of 10' to 15' is consistent with DMG measurements (see Refuse Area Slope and Terrace Drain Measurements section of this report), but conflicts with Cross Sections II&JJ of Exhibit 26, which appear to depict typical terrace drain width of approximately 45 feet. Construction design for CRDA-2 did not include installation of an underdrain. RSRDA Maintenance Items and Requests 1) Collection ditches along the toe of the refuse pile (Ditch UU to Pond 9 and Ditch SS to Pond 8) have partially silted in along some segments and should be cleaned out to ensure design dimension and positive grade to the sediment pond. 2) Please clarify the the discrepancy between approved version of Exhibit 6C and proposed TR-42 version of Exhibit 6C, regarding Ditch Segment F and the North Collection Ditch. In addition, please provide the P.E. construction certification for the constructed ditch. Please provide the clarification and certification prior to the Phase I bond release inspection. 11