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III. COMMENTS • COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during the <br />inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br />evidence supporting the enforcement action. <br />concentrated flow was noted in along the channel berms upstream of these silt fence segments. Also, it was <br />noted that a small ephemeral drainage merged with the west side channel berm near the upper end of the main <br />riprapped segment of Channel "H". Flow from the ephemeral drainage was not conveyed into Channel "H", but <br />was diverted along the west side channel berm, which may have contributed to the failure of the sift fence on the <br />west side of Channel "H". <br />Each of the three silt fences along the north side perimeter berm in SAE #1 had been pushed over (apparently <br />by pressure from build-up of sediment and runoff). The eastern-most and western-most of these three silt fence <br />segments had also been under-cut by flow, which may have happened either before or after the structures were <br />pushed down and over-topped. <br />The number and location of silt fence structures appears to have been in compliance with the approved permit, <br />but the structures as installed were unable to function as intended to filter sediment-laden flow during the runoff <br />event. The rainfall amount, intensity, and duration are unknown. Based on statements from Chuck Silengo of <br />CAM LLC, there was a fairly intense rain event on the night of August 2, which caused many of the small <br />ephemeral drainages in the permit area vicinity to flow. Ditches along Highway 139 were silted in and <br />subsequently cleaned out by DOT crews. Mr. Silengo indicated that he drove up the access road on the morning <br />of August 3 to check for problems resulting from the storm. Based on the condition of culverts, ditches, the <br />refuse area sediment pond, and reclaimed road slopes, he concluded that the storm did not cause problems that <br />required maintenance or repairs on the permit area. He did not walk all of the way up the reclaimed access road <br />to check the condition of the reclaimed portal bench area, however, having assumed based on site conditions <br />lower in the watershed that the storm would not have caused damage higher up. Apparently, no one had <br />observed the condition of the reclaimed portal bench after the August 2 rain storm until my inspection of August <br />16. <br />Photo DSC03321 shows the two Channel "H" berm silt fences; nearest is on west berm and furthest is on east <br />berm. Photo DSC03322 is a view along Channel "H", upstream of the silt fences. Photo DSC03323 shows <br />tilling along Channel "H" west berm. Photo DSC03329 shows small tributary channel junction with Channel "H" <br />west berm. Photo DSC03332 shows rill along Channel "H" east berm. Photos DSC03334 and DSC03337 show <br />the Channel "H" west berm silt fence; DSC03338 shows the Channel "H" east berm silt fence. <br />Photos DSC03340 and DSC03341 show the first silt fence along the north side berm, east of the Channel "H" silt <br />fences, and associated erosion. Photos DSC03343 and DSC03344 show the second silt fence along the north <br />side berm. Photos DSC03345 and DSC03346 show the eastern-most silt fence along the north side berm. <br />Specific abatement measures are addressed in the NOV. In addition to the specified abatement measures, <br />operator needs to ensure that replaced and repaired silt fence structures are properly installed and <br />securely trenched in. Measures to enhance the effectiveness or stability of the structures, including <br />installation of energy dissipater devices or structures in association with silt fencing, and/or installation <br />of multiple closely set silt fence structures in series should be given consideration. <br />Availability of Records <br />Required records were on file and up-to-date through the 2nd quarter, 2007. <br />Roads <br />Public land portion of haul road west of the waste disposal area and lower portion of access road to be retained <br />for the postmining land use have been properly reduced to 8 foot travel width. Ripped areas along the width <br />reduced segments were seeded with "Quickguard" cover crop in July, and the cover crop had recently <br />germinated. Lower- <br />4 <br />