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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. determination. The road provides access to BLM lands, and BLM had specifically requested retention of the concrete dip-section crossing and installation of the wing-walls. The following sections of the inspection report contain certain requests for submittal of bond release application and permit amendments. Informational requests are in bold print. Requested information should be provided as soon as possible, to allow us to proceed with issuance of a proposed decision. General Bond Release Inspection Considerations Pursuant to Rule 3.03.2(2), and in accordance with [he Guideline Regarding Selected Coa! Mine Bond Release /ssues, the Division considers the following items during any bond release inspection evaluation: (l) Results of past monthly inspections--- In the case of Roadside Mine, the Division has issued only one enforcement actionfor an "on-the ground" problem since active mining operations ceased in December, 1999. This was NOV CV-2000-001 which was issued February I I, 2000, for piping erosion that developed in the embankment of Sediment Pond 4, a[ the North Portals Coal Handling Area. The embankment was properly re-constructed, and the NOV abated and terminated within required time frames. Two enforcement actions have been taken by the Division during the past year, based on the fmancial status of Frontier Insurance Company, issuer of a $2,603,016.00 corporate surety bond held by the Division. These enforcement actions were upheld by the Mined Land Reclamation Board, but remain subject to judicial appeal. Review of past monthly inspections indicates that required envvonmental monitoring and site maintenance activities have been conducted th compliance with permit and regulatory requirements, and reclamation to date has been conducted in accordance with the permit specified reclamation schedule. (2) Surface and ground water monitoring data, and whether pollution of surface or subsurface water is occurring, the probability of such future pollution and the estimated cost to abate pollution--- Ten sedimentation ponds are in place at the mine to treat disturbed area run-off, and are authorized under the operator's CDPS discharge permit issued by the Water Quality Control Division. The ponds discharge very infrequently, and discharges which have occurred during recent permit terms have been in compliance with applicable discharge standards. There are two active mine-water discharge locations (001 and 002) authorized under the CDPS permit and the DMG permit, which are regularly monitored for compliance with [he CDPS permit and to demonstrate conformance with probable hydrologic consequences (PHC) projections requved by the DMG permit. Discharge Site 002 is the main point of discharge for water that accumulates in the South Mine workings. DMG has identified concerns with regard to the suitability of the dewatering mechanism (a siphon system) at this location (thebackfilled Northwest Intake Portal) for the long-term post mine situation. The approved permit contains plans for installation of gravitydrain pipe in the vicinity of [he North Decline reclaimed area, that will replace the siphon as the primary point of discharge. To date, quality of discharge water has been in compliance with CDPS permit limits and in conformance with PHC projections, and it is expected that furore long term quantity and quality of discharge will remain within the range observed to dale. A thud mine-water discharge site (004) was active at the North Portal mine, until the mine ceased operation and the pumps were shut down in December 1999. During active mining operations in the late 1990's, the Division had issued several