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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 />The NOV was written for improper surface drainage provisions at Refuse Sub-azea SA, and there were two <br />primary components to the NOV. First, a small depression that was approximately 3 feet deep at its <br />deepest point had been formed immediately to the north of the lazge temporary waste material stockpile <br />located in the central portion of Sub-azea SA, as a result of site grading activity. The depression was <br />formed by scrapers excavating material from the temporary stockpile and spreading the material in lifts on <br />the permanent pile area immediately to the north. The total area of the depression was approximately 30 to <br />50 feet wide by approximately 300 feet in length. Precipitation within this area, as well as precipitation on <br />immediately adjacent outslopes of the temporary pile would drain to the depression, resulting in a small <br />azea of ponding on the refuse fill. When first observed on July 9, there was a shallow puddle in the deepest <br />portion of the depression, apparently from moisture draining out of the temporary stockpile. Operator <br />indicated that, given the location of the temporary stockpile and the method of scraper excavation being <br />used to remove material from the stockpile, a similaz depression would exist until removal of the temporary <br />pile was completed, in approximately 3 weeks. <br />The depression was included as a component of the enforcement action, based on the requirement of Rule <br />4.09.2(7), that "...surface runoff from the fill surface shall be diverted to stabilized channels off the fill.." <br />The provision is intended in par[ to prevent ponding of water on the fill, which might negatively impact <br />stability of the fill. <br />The second component of the NOV was that the toe ofthe refuse fill side slopes as it is being constructed is <br />at a lower elevation than the constructed perimeter containment ditch. Because runoff from the pile surface <br />and outslopes does not drain into "a stabilized channel off the fill", the fill does not comply with the cited <br />requirement of 4.09.2(7). Plan view topography and Cross Section A-A' on permit Map 77A "Refuse Area <br />SA Site Plan" depict final refuse azea side slopes as draining into the existing stabilized containment <br />ditches. In the field, along the west side of the site a toe had been established at an elevation substantially <br />lower than the containment ditch, and the fill was being built up from that toe, such that runoff from the fll <br />surface would flow along the toe and ultimately into Sediment Pond SA, without entering the stabilized <br />channel. Toe slopes had not yet been established along the eastern perimeter of the fill due to the limited <br />quantity of refuse material placed to date. The construction process and/or disposal plan needs to be <br />properly amended to ensure that runoff from the pile surface will be safely diverted (withoutponding or <br />erosion) via stabilized channels off the fill, throughout the construction process. This may require <br />provision for stabilized interim ditches that aze sequentially replaced as the fill expands. <br />Abatement actions specified in the NOV include elimination of the depression on the surface of the pile by <br />August 15, 2002, submittal of a complete technical revision application addressing construction plan <br />modifications needed to ensure compliance with applicable water control provisions of the regulations by <br />August 1, 2002, and implementation of modified plans within 20 days of final approval of the technical <br />revision. <br />NOV CV-2002-017 <br />This enforcement action was taken for improper maintenance activities associated with disturbed area <br />collection ditches located on the Prep Plant bench, specifically eroded segments on two ditches and an <br />exposed PVC pipe segment within one of the ditches. <br />Improper ditch construction or maintenance which resulted in erosion of two sediment pond collection <br />ditches; and improper ditch maintenance which exposed a buried pipe segment which could have resulted <br />