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D <br />III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the <br />inspection and the facts or evidence supporting the enforcement action. <br />This was the 1st quarter complete inspection of the Roadside <br />Portals Mine, conducted on March 27 and March 31, 1997. Weather <br />was clear on the 27th, and partly cloudy on the 31st. Ground <br />conditions were dry in most areas. <br />Availability of Records <br />Records were checked in the mine office on March 31, and found to <br />be on file and up to date through the 4th quarter, 1996. <br />Roads <br />Minor rilling was noted on steep sections of the 2-West Portals <br />access road. Grading and water bar installation is warranted in <br />these locations. <br />The inside road ditch on the north side of the loadout bench, <br />adjacent to the conveyor transfer station was partially filled in <br />with coaly sediment, and cleanout was completed prior to the end of <br />the inspection. <br />Road surfaces and drainage features in general appeared to be well <br />maintained and in compliance. <br />Hydrologic Balance <br />Sediment Ponds <br />Pond 5 -- Dry. The operator has proposed certain <br />modifications to Pond 5, within TR-22, which was submitted in <br />partial abatement of NOV C-97-001. Upon approval of the <br />revision, modifications would be implemented to allow for a <br />portion of the pond to be used for surface detention and <br />treatment of minewater, prior to discharge to the Coal Canyon <br />drainage. Questions were raised during the Division's <br />adequacy review of the technical revision regarding the need <br />for vegetative stabilization of the embankment outslope, and - <br />the need for a stability analysis, to demonstrate a safety <br />factor of 1.3, with steady state seepage saturation <br />conditions. <br />During the inspection, it was observed that the existing <br />embankment adjacent to Coal Canyon drainage is approximately <br />l0 to 12 feet wide at its crest at the narrowest location, <br />with no apparent erosion on the outslope. The outslope <br />