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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 fact or evidence su~~ortinc7 th~ enforcement action. <br />restore es~gn cross sect ns. lrTSta ,repair or replace riprap as necessary to prevent <br />erosion from the f0 year 24 hour storm event runoff. <br />When observed on the morning of April 16, there was snowmelt runoff flow in the ditches <br />on both sides of Haul Road G, extending from the D Pit areas regraded in summer/fall of <br />2002, down toward Sediment Pond 005. Flow appeared to be 200 gpm or more in each <br />ditch. There was significant downcutting along each ditch extending for several hundred <br />yards from the lower end of the regraded spoils, down to and including a steep down drain <br />segment below a 36" culvert outlet above Pond 005. In some locations, riprap had been <br />washed out or undercut, and in other locations flow had bypassed riprap and eroded a gully <br />along the side of the riprapped channel. Gullying from 1 to 3 feet deep was common, with <br />the deepest incision along the lower end of the north side ditch relief outlet drain, where the <br />vertical sided gully appeared to be approximately 10 to 12 feet deep. In one location, just <br />below the north ditch relief outlet drain, a small sediment check pond had been completely <br />filled in with sediment and the riprapped spillway and riprapped drainage segment below <br />had been partially washed out. <br />Drainage from a large area of the regraded spoil had flowed into the north side road ditch, <br />rather than into an adjacent natural drainage channel at the lower end of the spoil. The <br />approved plan appears to have been for the flow to be directed into the natural drainage. It <br />appeared that the operator had attempted to install temporary berm or diversion features in <br />the summer or fall of 2002 to divert flow from the spoil into adjacent natural drainages, but <br />these temporary features were over-whelmed by the snowmelt runoff that found its way <br />into the north side road ditch. Disturbed flow from both the road ditches and the natural <br />ephemeral channels in the vicinity is captured by Sediment Pond 005. All of the runoff <br />associated with the eroded ditches described did end up in Pond 005. <br />On the morning of April 16, although the disturbed flow entering Pond 005 was highly <br />sediment laden, the pond discharge outlflow (estimated to be 400 gpm or higher) appeared <br />relatively clear. snowmelt runoff inflow rate is assumed to have been equivalent to <br />outlflow, since the discharge was from flow over the top of the primary spillway riser. <br />Samples 057-005-1 (for total suspended solids) and 057-005-2 (for total settleable solids) <br />were taken from the discharge outlet at 4:15 p.m., on April 16. The samples were kept in <br />my possession in an iced cooler, and delivered to Brian Bauer at Grand Juriciion <br />Laboratories in Grand Junction, at 9:00 a.m., on April 18. <br />Regulation sections cited included various provisions of Rule 4.03.1 pertaining to general <br />haul road construction and maintenance; as well as construction, maintenance, and erosion <br />control requirements pertaining to disturbed area haul road drainage structures. Provisions <br />of 4.14.1(2)(b) and 4.14.2(5) were also cited, due to the observations indicating that <br />improper spoil grading had (apparently unintentionally) concentrated flow within road ditch <br />segments, almost certainly exacerbating ditch erosion. <br />Permit Sections cited were Exhibits 13-2,13-10, and 20-2. Exhibit 13-2 is titled Surface <br />Hydrology Map, certification date of Dec. 7, 1998. The map depicts Haul Road G ditches <br />above the 36" culvert as Category "C" ditches. Exhibit 13-10 is titled Typical Road <br />Details, certification date of Nov. 5, 1990. The exhibit specifies that roadside ditches <br />would be constructed as "V" ditches with 2:1 side slopes. Category "C" ditches are <br />3 <br />