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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. A complete quarterly inspection of the Roadside North and South Portals Mine was conducted by Dan Mathews of DMG. Operator representatives Tonya Hammond and Jim Stover were present brieFly during the inspection, but most of the inspection was conducted with no operator contact present. Field inspection was conducted December 13, 14, and 17, and office records were reviewed December 18. A follow-up inspection was made on the afternoon of December 23, to check abatement of NOV CV-2001-017. Weather was clear and cold, with patchy snow cover in some areas. Inspected locations included the 2- West Portals and South Fan site, the North Decline, CRDA refuse piles and adjacent areas, North Portal Area, overland conveyor corridor and unit train loadout, and the South Portal facilities area including the RSRDA refuse pile and the backfilled Northwest Intake Portal. In general, reclamation operations are being conducted in conformance with the approved reclamation schedule, with the exception of certain facilities for which the operator has requested extensions to the schedule. The request for modification of the reclamation schedule remains under review by the Division. Major earthwork tasks associated with final reclamation of the CRDA refuse areas and Coal Creek permanent diversion channel segment are to be completed during [he F' quarter, 2002. The status of reclamation activities in the various facility locations is outlined below. Site maintenance requests and recommendations are in italics. 2-West Portals Inspection was begun at 9:30 a.m. on Dec. 13. Weather was clear and very cold. Ground was frozen, with approximately 2 inches of snow cover on north and east facing slopes, patchy snow cover in other areas. Since the previous inspection of the area, the substation site had beenbackfilled and graded, seeded and straw mulched, and silt fenceberm sediment controls installed. A properly roughened seedbed had been created, apparently by dozer ripping. The power line to the 2-West Portals area had been removed. The portal areas and stockpile location reclaimed in the fall of 2000 appeared stable, with no visible cracking, slumping, or other indicators of instability. A promising first yearrevegetation stand was established in most locations. The permanent channel relocation segment and associated road dip appeared stable. Silt fence maintenance is needed at the lower portal area and the substation site, where the silt fence was apparently knocked down by cat[!e. South Fan and associated disturbances The fan area was reclaimed in the fall of 2000. The site was free of snow coves slopes appeared stable with a promising first year revegetation stand. Silt fence and berm sediment controls were intact and functional. Conditions at the reclaimed soil borrow area similar to fan site. 8 mule deer were bedded in junipers adjacent to the reclaimed fan site. The 5-pole power line segment from the line up the main Rapid Creek road to the South Fan area is still intact. This line is identified on Exhibit 57 of the permit as a "Public Service Power Line, Unaffected by