Laserfiche WebLink
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 />inspection report issued 8/29/97 and afollow-up report addendum of October 17, 1997). <br />Documentation of proper pile construction, slope gradient, and drainage structure <br />construction, as well as water level monitoring and engineering certification was also <br />included in the 1997 reports. DMG verification of proper cover soil replacement was <br />provided in inspection reports of June 29, 1994 and June 8, 1995. <br />The upper two benches of CRDA-1 and CRDA-2, and the slopes of the RSRDA were <br />reclaimed in 2002. The Division has evaluated compliance with construction and <br />reclamation specifications during and after completion of the reclamation work, and the <br />evaluations are documented in various 2002 and 2003 DMG inspection reports. Diversion <br />and perimeter ditch specifications were checked and documented in inspection reports of <br />May 5, 2003, April 15, 2003, and January 31, 2003. Bench heights and slope gradients <br />were checked and documented in the April 15, 2003 inspection report. Cover soil <br />replacement thickness was checked and documented in the January 31, 2003 inspection <br />report. Compliance with required engineering/construction certification and water level <br />monitoring requirements (showing that critical levels for pile stability have not been <br />exceeded) is documented in the April 15, 2003 inspection report. Revegetation efforts and <br />apparent success has been evaluated in numerous reports, including April 15, 2003, and <br />June 11, 2002. <br />i) Cover Material and Topsoil Placement <br />Approved non-toxic cover soil thickness is 24" at CRDA-2 and 18" at CRDA-1 and the <br />RSRDA. A variance from the 4 foot cover requirement was approved by the Division <br />following amulti-year field trial, prior to initial reclamation in 1994. Due to shallow soil <br />cover in the refuse areas, much of the reclamation soil was obtained from approved borrow <br />areas. Because of the arid environment and nature of the parent materials in the permit <br />area, soils typically have elevated levels of salts, and high sodium adsorption ratios. Native <br />vegetation communities and the species included in the approved permanent seedmixes at <br />Roadside are adapted to these conditions. <br />The top 6" layer of the specified cover soil thickness is to be top-dressing quality (EC of 8 <br />or less and SAR of 12 or'lessl, with the remainder required to meet subsoil quality criteria <br />(EC of 15 or less and SAR of 25 or less). Recent sampling completed by the operator has <br />shown that surface topdressing obtained from topsoil stockpiles and placed on portions of <br />CRDA-2 in 2002 exceeded specified topdressing limits for EC or SAR. Similarly, some <br />borrow material soils placed on portions of the surface of CRDA-1 also exceeded the <br />specified topdressing limits. Borrow soil material placed on the RSRDA refuse area was <br />higher quality material, and met the specified topdressing criteria. Documentation of the <br />soil material quality is provided in recent (Technical Revision 42) updates to Appendix 9-7 of <br />the permit application. Future evaluation of vegetative development on portions of the <br />refuse areas with elevated salinity levels will be necessary to determine whether mitigative <br />treatments will be warranted. Quantitative documentation of successful vegetative cover <br />establishment will be required prior to any release of reclamation liability for topdressing <br />replacement. <br />4 <br />