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Chi Chi Ray, Oakridge Energy, Inc. <br />C- 1992 -080 <br />August 29, 2012 <br />Page 3 of 4 <br />full length of the area in question. We observed that flow from the Carbon Junction Arroyo and <br />a smaller unnamed drainage from the south have been pinched against the southern side of the <br />canyon by the man -made feature, and that significant head- cutting erosion has occurred at the <br />downstream terminus of the feature, where the flow returns to the elevation of the natural <br />channel. <br />During the inspection, we discussed various options for restoring surface runoff to the natural <br />channel. The man -made feature, whether a constructed berm or the remnant of a road bed, is <br />well- vegetated and appears to be stable, with the exception of the erosion mentioned above. <br />Rather than disturb the entire feature by grading it into the adjacent hillside to the south, the <br />Division agrees that an acceptable alternative would be to breach the feature in two locations: at <br />the upstream end, and at a point where the side drainage enters from the south. These actions <br />should serve to bring an end to the continued concentration of flow and erosion that occurs. <br />This area of the Carbon Junction drainage is addressed in the February 2008 "Abridged Permit <br />Document" submitted for Permit Renewal No. I It appears that Oakridge's intent has been to <br />restore the drainage to the natural channel, with riprap lining in two areas. Page 5 -16 of the <br />document includes the following: <br />"As shown on the Hydrology map, the Carbon Junction Canyon will be restored in its <br />original channel for the majority of the length upstream from the permanent diversion. <br />For this area, no lining will be needed. However, two portions of the channel, one near <br />the upper end of the diversion, and the other near the lower sump, will need to be lined <br />with riprap of D50 of 1.5 feet. A layer of 1.5 feet to 2.5 feet will be placed in a channel <br />width of 14 feet. No underlying falter will be employed in these areas since the existing <br />material is rocky. The approximate lengths of the two upstream lined areas are 150 feet <br />and 350 feet. " <br />Based on what we observed during the July site visit, it does not appear that the reclamation <br />work described in the paragraph above has been completed. Please submit an application for a <br />Minor Revision to the permit which addresses restoration of the Carbon Junction Canyon to its <br />original channel. The application should also include general work plans proposed for the <br />breaching of the man -made feature to restore flow from the side drainage into the natural <br />channel, and for repair of the erosional feature that has developed at the man -made feature's <br />downstream terminus. Pertinent features of the Upper Carbon Junction Canyon are identified on <br />the third Google Earth photo enclosed with this letter. <br />East Collection Channel and Ditch <br />Removal and reclamation of the sediment ponds and ditches was accomplished by OEI in 2009. <br />During the July inspection, we observed that portions of the East Collection Ditch and the East <br />Collection Channel — Lower had not been reclaimed during the 2009 effort. As with the wells, <br />Oakridge felt that because these segments lay within the bounds of the Ewing Mesa No. 1 Pit, <br />they were the responsibility of that permit to reclaim. We have reviewed the construction <br />materials permit, and find that it specifically states that the ditch remains part of the coal permit. <br />Unless Oakridge can document otherwise, we believe the reclamation of the East Collection <br />Channel and East Collection Ditch were and continue to be part of the Coal Permit. <br />