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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 />From Permit page 13-21, construction specifications for CRDA-1 call for minimum 10' wide <br />terrace drains on 30 foot vertical intervals (except Bench 1 height of 50'). Maximum slope <br />gradient of 50%. CRDA-2 specifications are the same, except for maximum slope gradient <br />of 40°~. There is conflict between text and Exhibit 53 regarding required terrace drain <br />width for CRDA-2, which will need to be resolved (see previous section). <br />On CRDA-1, Bench 4, average slope was 45%, and average estimated bench height was <br />31'. Bench 5 average slope was 32% and average height was 19'. Terrace drain widths <br />ranged from 10' to 11'. Maximum estimated bench height was 34', and maximum bench <br />slope was 48%. The upper benches of CRDA-1 reclaimed in 2002 appear to have been <br />constructed in general conformance with the referenced design specifications. <br />On CRDA-2, Bench 4, average slope was 40%, and average estimated bench height was <br />30'. Bench 5 average slope was 33%, and average estimated height was 18'. Terrace <br />drain widths ranged from 12' to 15', averaging 13.5'. Maximum bench slope was 44%; <br />maximum bench height was 35'. The upper benches of CRDA-1 reclaimed in 2002 appear <br />to have been constructed in general conformance with the referenced design specifications, <br />although the referenced terrace drain width specification design inconsistency needs to be <br />resolved. <br />From Permit page 14-6, and Exhibits 6C and 26, design specifications for the RSRDA <br />include 2, 10'-15' wide terrace drains, with bench slopes of up to 50%, and bench height <br />of up to 40 feet. Based on the data collected, Bench 1 average slope was 46%, and <br />average estimated height was 42'. Bench 2 average slope was 38°k; average height was <br />28'. Bench 3 average slope was 40%; average height was 36'. Maximum bench slope <br />was 53%, and maximum bench height was 50' (lower bench in one location). Terrace drain <br />width ranged from 11 to 14 feet. The RSRDA benches reclaimed in 2002 appear to have <br />been constructed in general conformance with the referenced design specifications. <br />However, there is a discrepancy between terrace drain width specification in permit text <br />and Exhibit 26, that will need to be resolved. <br />13 <br />