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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 />depicted as having a design depth of 3 feet. Haul Road G "As-Built" Exhibit 13-19.3A <br />depicts a riprap down-drain segment below the check pond on the north side of the road, <br />and a riprap dawn-drain segment on the south side of the road immediately up-gradient and <br />down-gradient from the 36" CMP (Sta. 57+50). Both of these riprap segments were <br />compromised by the runoff. In some segments the riprap was washed out; in other <br />segments riprap was silted in and flow jumped outside of the riprapped channel. Along <br />some segments there was side-cutting erosion and in other segments the riprap had been <br />undercut. Riprap that had been placed along various other road ditch and relief drain <br />segments (and which also was compromised by the flow event) was not depicted on the <br />map exhibits. However, permit text does reference the use of riprap where necessary. <br />Specifically, the following applicable narrative is from permit page 13-18: <br />Water from a fill will be released below the fi/l through conduits or in adequately <br />lined channels... When haul road drainage ditches discharge onto open terrain, a <br />number of measures will be taken to minimize erosion including revegetaion, straw <br />dikes, and riprap. When the road ditch discharges onto a disturbed area, the terrain <br />wi/l be revegetated or riprapped, if necessary, to control runoff and <br />erosion...Orainage from haul roads within the areas disturbed by mining and <br />reclamation activities will be constructed to meet the requirements of 4.05.2 and <br />such roads will at a minimum be constructed and maintained to minimize erosion of <br />the disturbed area. <br />Exhibit 20-2 is the approved Postmining Topography Map. The map depicts Road G as <br />having been obliterated within the D pit regraded spoil area, and shows two reclaimed area <br />drainage channels converging at the lower end of the graded spoils, with runoff from the <br />regraded slopes directed into the natural drainage at the toe of the spoils. Road G is <br />depicted as "permanent" up to a point approximately 200 to 300 yards below the reclaimed <br />D pit area (halfway between the 36" CMP and the toe of the graded spoils). Grading had <br />been largely completed within the D Pit area in the summer/fall of 2002. However, Road G <br />had not been obliterated within the reclaimed area, and the final drainages had not been <br />shaped or riprapped. <br />Digital Photos 435 through 460 were taken on the morning of April 16, and depict various <br />locations within the graded D Pit spoils, and road ditch segments and ditch relief down <br />drains along Road G between the D Pit graded spoils and Pond 005. <br />By the afternoon of April 17, 2003, the operator had managed to access the D Pit graded <br />spoils area with a backhoe, despite extremely muddy conditions and flowing ditches, and <br />had been able to make remedial improvements to the drainage situation. First, a short <br />segment of temporary ditch had been dug across the road within the graded spoils area to <br />direct all drainage from the graded slopes south of the road across the road to the north. <br />Second, a berm had been built up north of the road at the toe of the graded spoil, to divert <br />all drainage from the spoil away from the road ditches and into the natural drainage channel. <br />Digital photos 464 and 465 depict the site on the afternoon of April 17, following <br />construction of these remedial measures. Given the difficult conditions, the operator took <br />considerable initiative in conducting this work, and it would appear likely that the effort will <br />4 <br />