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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 />include locations at the 016 Discharge Site SAE (material wind damaged, torn off stakes in some <br />locations, and one end stake broken off), upper silt fence at "B" substation site (fabric wind damaged, <br />needs to be replaced), 2-West Portal lower portal (material torn off several of the stakes), 2-W Portal <br />Substation SAE (one of the silt fence end stakes needs to be re-set), South Fan area (two silt fences <br />wind damaged and need to be replaced), North Portal Area silt fence functional but material pulled away <br />from stakes at one end. <br />Coal Creek permanent diversion segment had been properly regraded, and segment of bank adjacent to the <br />Pond 10 embankment had been properly protected with riprap prior to the inspection. There was moderate flow <br />in the channel on the morning of 9/22. <br />Sediment Ponds 6, 8, 10, 1&2, and the evaporative sewage lagoons contained shallow puddles. Pond 11 <br />contained a pool approximately 7 feet below the level of the embankment; Pond 9 contained a pool at the <br />approximate level of the primary spillway pipe (valve closed; no discharge). Ponds 7, 13, and the North Decline <br />SAE sumps were merely muddy, with no standing water. The CBA-1 SAE sump contained a pool of water, but <br />was being siphoned out with a hose on 9/29; discharge water was clear. <br />Diversion and collection ditches and berms were in general properly maintained and functional. Most of the <br />maintenance work necessitated by previous storm events had been completed; work continuing in a few <br />locations. The East Wing of the North Portal Area upper diversion was silted in along the low gradient <br />middle segment, in one location depth appeared to be 1 foot or less (design depth is 1.3 feet). The <br />segment needs to be maintained as warranted to restore design specification. <br />There was small flow out of the north portal openings at the South Portal Area, which was properly draining into <br />Pond 8 via the portal bench drain and buried pipe. <br />Minewater Discharge Site 016 was discharging clear flow, approximately 300 gpm <br />Backfillina and Gradin <br />The various backfilled and graded areas were walked, and no slumping, cracking, or other signs of instability <br />were apparent. One gully which was caused by the intense rainfall in late July is still evident on the <br />backfill in the North Portal area, in the vicinity of the former portal decline location. This gully needs to <br />be repaired. <br />Processino Waste <br />Most areas of both CRDA waste disposal sites and the RSRDA waste disposal site were walked. There were no <br />indications of instability or excessive erosion. Diversions, perimeter ditches, and terrace drains appeared to be <br />properly maintained and functional, with a couple exceptions. Work was nearing completion on cleanout of <br />the CRDA-2 upper diversion ditch described in recent inspection reports. This work was temporarily <br />halted due to rain the night of 9/21 and morning of 9/22 that caused excessively muddy conditions, but <br />completion of repair was projected by 9/30. The riprap energy dissipator structures at the outlets on <br />both wings of the diversion will also need to be repaired; operator has indicated access for repair of one <br />of the outlets may be problematic. <br />On CRDA-1, water from the 9/22 rainfall was noted to have ponded in a couple locations along the upper <br />terrace drain, on the northwest section of the disposal pile. Ponding was noted along a 50 foot segment <br />at the upper end of the terrace drain, and along a 150 foot segment at the lower end of the terrace drain, <br />near the inlet to the NW perimeter collection ditch. This terrace drain needs to be regraded to establish <br />positive grade to the perimeter collection ditch. <br />4 <br />