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3 <br />1. Depiction of a road ditch (Ditch HRD-A2) entering Pond 006 on the as-built <br />certification (Exhibit 13-13.1), whereas the ditch actually bypasses the pond, <br />2. Lack of depiction of culvert F-3 on the Mine Entrance Haulroad certification, <br />3. Lack of depiction of silt fences at culvert and ditch outlets on exhibits ]3- <br />12.2, 13-13.2, and 13-13.3. <br />The ditch and culvert mentioned in items 1 and 2 above are designed and constructed as <br />approved in the PAP. Design parameters for these structures can be found in Tab 13, <br />Attachments 13-7 and 13-10 of the PAP. The on-the-ground location of the structures is <br />indicated on the Surface Hydrology map in the PAP (Exhibit 13-2). The silt fences <br />mentioned above are not designed structures and are not represented on a map. <br />Rule 4,.03.1(d) indicates that the design, construction, and reconstruction of haul roads shall <br />be certified by a professional engineer, "if required by the Division for good cause shown" <br />(emphasis added). The Division reyuired certification of the Mine Entrance Haulroad and <br />Haul Road "A" following construction. The certifications reviewed during the March 31, <br />1995 inspection were submitted in response to this requirement. Subsequent changes to the <br />road drainage systems were constructed following approval of designs in the PAP. The <br />Division did not require the operator to revise the as-built certifications for the roads. <br />Therefore, the operator is not in violation of Rule 4.03.1(1)(d). The as-built certifications <br />required by the Division under Rule 4.03.1(1)(d) are in the approved PAP. <br />As noted in the Division inspection report following the March 31, 1995 inspection, the <br />Division has instructed the operator to revise the certifications in question. The Division <br />has required these revisions be submitted prior to June I5, 1995, as discussed in the May <br />5, 1995 inspection report. The depiction of the culvert and ditch mentioned above will be <br />revised. The Division does not typically require that structures with no engineering designs, <br />such as silt fences, be indicated on road certifications. Since these structures do not have <br />design specifications, there is no point in having an engineer certify their construction. <br />By requiring revision of the road certifications, the Division will adequately address the <br />concerns identified during the March 31, 1995 inspection. However, since there is no <br />violation of Rule 4.03.1(1)(d), enforcement action would not be appropriate. <br />