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<br /> <br />Memo to File C-81-019 - 3 - July 6, 1993 <br />Damage seems to have occurred in two forms: (1) erosive <br />disturbances to undisturbed areas below the topsoil stripping area <br />and below the South Collection Ditch breach found on May 5, 1993, <br />and (2) disturbed area surface runoff leaving the permit area and <br />apparently entering nearby Goodsprings Creek. <br />Extent of the damage below the topsoil piles and above the South <br />Collection Ditch included the erosional gullies that formed in this <br />undisturbed area, and the areas downhill from the gullies where <br />sheet flow deposited sediment onto undisturbed areas and caused <br />minor erosion. From photographs, it is apparent that the three <br />large gullies measured a total of approximately 1500 square feet. <br />From photographs and staff testimony, it is apparent that the three <br />areas of disturbance below the gullies each averaged 275 feet by <br />two feet wide, or a total of 1650 square feet. Adding this to the <br />1500 square feet of gullies brings the total extent of disturbance <br />above the South Collection Oitch to 3150 square feet. <br />Extent of the damage below the South Collection Ditch breach was <br />estimated from photographs and staff testimony as 1/2 mile long and <br />two feet wide, or 5280 square feet. As such total areal extent <br />of damage pertaining to this NOV is apparently 8430 square feet. <br />Additional damage consisted of untreated runoff apparently entering <br />Goodsprings Creek. To date, no data indicating the amount of <br />increased sediment levels in Goodsprings Creek are submitted to <br />this NOV file. As such, this component of damage, in terms of <br />impact on the public or environment, is considered low at this time. <br />Duration of the event causing the erosive damage below the topsoil <br />stripping area and above the South Collection Ditch appears to have <br />lasted from at least May 5, 1993 (the date of the inspection when <br />this problem was first noticed) to"May 27, 1993 (the date of the <br />inspection in which the Division verified an upland diversion had <br />been constructed). The operator should be asked how long before <br />May 5, 1993 the erosion began to occur. <br />Duration of the South Collection Ditch breach apparently lasted <br />approximately forty days, from early April to mid-May, as the <br />operator states that "Early in April, Juan Garcia of Colowyo first <br />noticed the problem areas...The ditch repair portion of the NOV was <br />completed on May 19, 1993." <br />Extent of the damage appears low. Duration, however, is high. As <br />such, because of the high duration of several events occurring that <br />the regulations were designed to prevent, seriousness is set at <br />moderate and assessed a civil penalty amount of $500.00. <br />