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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 />Miscellaneous Areas Near CRDA-1 <br />Additional sites in the vicinity of the CRDA refuse piles for which bond release is requested are CBA-I, <br />former Topsoil Pile 5, former Topsoil Pile 6, and reclaimed Access Road 10. Each of these small sites was <br />reclaimed at the same time that the CRDA lower benches were reclaimed, and based on observations made <br />during the bond release inspection, they appear to have been properly graded to blend in with adjacent <br />terrain, in conformance with the approved permit. An apparently effective cover of perennial vegetation <br />has been established on each of these areas. At CBA-I, a sediment containment ditch and incised sediment <br />trap (CBA-I Sump) remain, and will need to be eliminated once appropriate sedimentation demonstrations <br />have been made, prior to final (Phase 11I) bond release. <br />(9) Drainage control for the reclaimed area, including approvedupslopedlversions. <br />Drainage and sediment control structures associated with each of the various locations for which Phase I <br />bond release was requested appeared to be properly maintained and functional. Disturbed area drainage in <br />each of the locations is either routed to a sedimentation pond or other permit specified sediment control <br />structures, including containment sumps, straw bale dikes, and silt fencing. For a fewsmall reclaimed <br />areas, demonstrations have been made by the operator showing that sediment control measures are not <br />necessary to meet applicable water quality requirements. At CRDA-2, the permit requires installation of a <br />new upland diversion ditch in association with fmal reclamation, due to concerns with the suitability of the <br />existing ditch as a permanent structure. At both CRDA-I and CRDA-2, upper sections ofexisting <br />perimeter collection ditches will need to be graded to final design configuration andriprapped in <br />association with final reclamation of the upper benches. Adequate bond will need to be retained for each <br />location where temporary sedimentation control measures are in place, to ensure that sufficient funds will <br />be available to eliminate the structures when appropriate, in the event of bond forfeiture. <br />Summary <br />This report summarizes the results of the Division's Phase I bond release inspection and evaluation. The <br />report contains requests for additional information and amendments to the permit and bond release <br />application. The report incorporates certain requests and observations made by OSM and BLM personnel <br />during and subsequent to the inspection, but it is possible that either of the agencies may have additional <br />concerns regarding the bond release that have not been brought to our attention. Final approval of this <br />bond release application cannot occur without concurrence from OSM and BLM. <br />14 <br />