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III. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. This was the complete inspection of the Roadside North and South Portals Mine, for the 1" Quarter, 2002. Field inspection was conducted on March 25 and Mazch 28; office records were checked April 1. Weather was cloudy with light showers on Mazch 25, cleaz and mild on Mazch 28. Reclamation projects were continuing at both CRDA refuse piles and the RSRDA refuse pile, and earth moving operations had been initiated in the North Portal Facilities Area. Tonya Hammond of Snowcap Coal was present during portions of the inspection. Availabiliri of Records Records were checked on April 1, and found to be complete and up-to-date through the d" quarter, 2001. In addition to records typically checked, it was noted that the operator also hadborrow azea soils data and initial GRDA-1 and CRDA-2 re-spread data on file. Operator pointed out that sampling data had indicated extremely high SAR valties within portions of Topsoil Stockpile No. 2, and also adjacent to the Coal Gulch channel within soil borrow area CBA-2. Review of permit soils data reveals that one of the two samples originally reported for Stockpile #2 had indicated very high SAR level and both samples had indicated mazginal EC levels. Operator had discontinued excavation from Stockpile No. 2 upon recognition of the high sodium problem, and had avoided high SAR zones immediately adjacent to the channel in the borrow azea. They indicated that some blending of high EC and SAR soils with better quality material had been conducted during re-spread operations on CRDA-2. Additional sampling was to be performed on re-spread surface soils, to identify azeas, if any, where permit specified suitability levels for EC or SAR were exceeded. Native soils in the permit azea exhibit relatively high levels of salinity and sodium, and most of the plant species included in the seedmix aze adapted to such conditions. DMG requests that, upon completion otthe initial sampling associated with the CRDA and RSRDA reclamation projects, a minor revision report be prepared and submitted that summarizes the sampling results and assesses the extent to which replaced soils met or did not meet permit specified subsoil or topsoil quality limits. Any "eaceedance areas^ should be delineated on appropriate reclamation maps, with SAR and EC levels indicated. The report should include a discussion of measures taken during salvage operations to identify and avoid or mitigate unsuitable soil material, and should outline proposed future monitoring as warranted and potential mitigative measures. The analysis reports with sample locations and sampled depth increment identified should be included with the report. Given the high salinity and sodium levels indicated within portions of Stockpile #2, additional sampling of the pile would appear to be warranted to identify the extent of unsuitable zones within the pile. In addition, review of permifsoils data indicates high (although not extreme) SAR levels within some portion of Stockpile # 3, (northeast of the North Portal Coal Yard). Additional sampling of zones within Stockpile #3 should also be conducted. Depending on the results of additional sampling of Stockpile #2 and Stockpile #3, availability of alternative sources of better quality topdressing to replace the quantity of unsuitable material in the stockpiles should be assessed, and an appropriate technical revision plan should be submitted prior to topsoiling of the North Portal disturbance area. The technical revision plan should document the suitability of any proposed substitute topdressing material, (with representative analyses for pH, EC, SAR, texture, and fertility. In addition, the plan should address the final handling of unsuitable soils within Stockpiles #2 and #3.