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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 />slope gradients; terrace drain spacing, slope and dimension; diversion/collection ditch <br />dimension, shape, and gradient; and cuh~ert sizing. <br />As a result of the special focus inspection, NOV C-97-016 was issued for improper diversion and <br />collection ditch construction or maintenance. The NOV applied to a number of locations on <br />CRDA-I and CRDA-2 perimeter ditches, which required maintenance or repair, and to the <br />CRDA-2 upper diversion ditch, which required substantial reconstruction. Ultimately, a Failure to <br />Abate cessation order was issued (CO-98-001). The abatement work was completed on January <br />22, 1998, and an amended CRDA-2 upper diversion certification was submitted on January 23, <br />1998. The enforcement actions were terminated on that date. <br />Observations made during the bond release inspection on August 14,2001, indicated that the <br />perimeter ditches and CRDA-2 upper diversion ditch were properly maintained and functional. <br />Due to concerns identified by the Division regarding the suitability of the existing CRDA-2 upper <br />diversion as a permanent structure, a new upper diversion design has been approved and will be <br />constructed during CRDA-2 final reclamation. <br />Reclaimed area slope compliance evaluation conducted in 1997 for CRDA-2 included data from <br />four slope transects, and included the following summary statement: <br />Wi[h only a couple ojvery minor excep[ions (within the probable error range ojthe <br />measurement [echnigrtes employed) reclaimed slope gradients, bench heights, and <br />Terrace drain dimensions were within [he design parameters specified in [he permi[ <br />narrative. Reclaimed slopes and terrace drains evaluated on CRDA #1 are judged to be <br />in compliance with the approved plan. <br />Reclaimed area slope compliance evaluation for CRDA-I included data from two slope transects, and <br />included the following summary statement: <br />Reclaimed slopes and [errace drains evaluated on CRDA-1 are judged [o be in <br />compliance with the approved plan. <br />During [he 1997 evaluation, monitoring records associated with 30 piezometers that had been installed on <br />CRDA-1 in 1994, in association with a stability evaluation, were reviewed by the Division, in conjunction <br />with the slope compliance evaluation. The Division concluded at that time that monitoring had not <br />documented problematic ground water elevations, although one particularpiezometer (#307) had exhibited <br />constriction or obstruction on occasion, which resulted in an incomplete data record for that particular <br />piezometer. This was not judged to be a critical deficiency, and replacement of thepiezometer was not <br />requested, unless "future changes in hydrologic characteristics or other stability indicators...warrant <br />reconsideration". Based on review of subsequentpiezometric monitoring, quarterly certifications, and <br />observations of the pile during regular monthly inspections and the bond release inspection, the 1997 <br />assessment remains valid. No indications of mass instability have been observed. Only limited minor rill <br />erosion has been observed (outslope of CRDA-2 bench 3), and the operator has taken appropriate <br />remedial measures. <br />13 <br />