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z - <br /> III. COMMENTS-COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made during the <br /> inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br /> evidence supporting the enforcement action. <br /> operator by construction of a"V" shaped TRM lined extension of the PM-10 channel, extending <br /> approximately 45 feet up through the slope segment that had eroded (Photo Ws 468 and 469). <br /> The regraded landfill terrain does not precisely conform to the grades depicted in approved <br /> designs. Map Exhibit 13-2A shows Channel PM-10 extending up through the upper valley <br /> almost to the drainage divide, and design Exhibit 7-20 indicates a grass lined "V" shaped <br /> channel, 1.1' deep for Channel PM-10, with a 13.9% slope. In actuality, the PM-10 channel <br /> extends only through the short lower reach of the graded landfill site, while the remainder of the <br /> upper PM-10 drainage could be described as a moderately steep valley headwall slope at the <br /> upper end near the drainage divide, a low gradient swale feature through the middle section, and <br /> the short, steep, gully repair channel section at the lower end. Inclinometer field measurements <br /> indicate a 16% slope through the steep upper segment near the divide, and a 21% slope through <br /> the steep TRM channel segment at the lower end of the site (in both cases, approximately 6% to <br /> 8% steeper than design grade). The steep west facing valley sideslope was measured at 3 1% in a <br /> typical location, which corresponds closely to slope grade indicated on Map Exhibit 13-2A. <br /> Photo#465 is a view from the low gradient middle segment of the drainage looking up toward <br /> the valley headwall slope and the drainage divide; Photo Ws 466 and 467 are views down <br /> drainage from the headwall slope. Photo #470 is of the west facing side slope. <br /> Despite the observed variations from approved designs, the regraded landfill area appears to be <br /> stable and adequately blends into the adjacent terrain. Good to excellent first and second <br /> growing season vegetation cover has been established in all areas, except the TRM channel <br /> segment that was only recently installed. Minor rills were noted in some locations along the <br /> slope in the upper reaches of the drainage, but initial (first growing season) vegetation <br /> establishment is good and it is expected that vegetation cover will be sufficient by next growing <br /> season to prevent further erosion. Based on observed performance of TRM lined channel <br /> segments in similar locations, it is expected that the TRM section of PM-10 at the lower end of <br /> the reclaimed landfill site will function well, and prevent recurrence of the gully erosion <br /> observed in the location earlier in 2009. Channel capacity conforms to the approved PM-10 <br /> design. For the reasons described,based on site inspection the Division's preliminary <br /> determination is that the reclaimed landfill site has been regraded to approximate original <br /> contour, and qualifies for Phase 1 bond release. <br /> Permanent Channel PM-12A <br /> The final area included in the SL-4 bond release request is a narrow corridor that extends from <br /> Road E-1 down-slope to the vicinity of the South Road, in the southern part of the permit area. <br /> 7 <br />