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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 inspection <br />and the facts or evidence supporting the enforcement action. <br />Status of the various mine portals was assessed during the inspection. The North Mine (Cameo) portals <br />appear to have been sealed and plugged with dirt backfill in compliance with permit requirements. <br />Concrete seals have been installed in the main South Mine Portals, approximately 100 feetinby the portal <br />openings, but the portals outby the concrete seals have not been plugged. The openings have been <br />temporarily secured to prevent entry. The shaft at the South Fan site was plugged and has been covered by <br />reclamation backfill, as have both portals at the 2 West Portals site. <br />The Northwest Intake portal (from which the siphon pipe that leads to Discharge Si[e 002 emerges) was <br />plugged in 1994 with dirt backfill. A settling crack a couple inches wide by, apparently, up to two feet or <br />more deep was observed during the inspection on October I5, along the upper perimeter of thebackfilled <br />portal opening. The crack had been filled in when 1 re-inspected on August 24. Tonya Hammond <br />indicated the crack had been opened up and filled in with soil, and tamped in with a shovel handle for <br />compaction. She said the crack did not open into a larger void. The Division believes it would be prudent <br />to withold Phase I' bond release at this time for the Northwest Intake, to ensure that the crack was not <br />indicative of instability of the portal backfill. <br />Both BLM and OSM have requested clarification regarding portal sealing procedures, and have indicated <br />that failure to provide such information could affect their concurrence on a bond release approval proposed <br />decision. Permit Figure 14-2 provides generalized design information for portal seals. Supplemental notes <br />on the figure provide additional information, but the notes are somewhat confusing, in that the various <br />portals referenced are all described as "backfill seals". It is the Division's understanding that the NW <br />intake and 2 West Portals were backfill only, whereas concrete seals have been installed in the main South <br />Portals, which are to be backfilled outby the seals to the portal openings. The Division requests that a <br />minor revision application to amend and supplement Figure 14-2 be submitted as soon as possible. <br />The revision application should provide "as built" sealing backfill details for each mine opening at <br />Roadside, including the South Portals, North Portals, 2 West Portals, South Fan shaft, and <br />Northwest Intake. The amendment should include information on type, thickness and installation of <br />seals (if any), volume and linear extent of backfill and method of placement, and the date that work <br />was performed. Finally, the submittal should provide detail for any portal closure work that remains <br />to be done (i.e. placement of backfill outby the concrete seals at the South Portals). <br />There were no structures associated with various other locations for which Phase I bond release was <br />requested. The reclamation cost estimate prepared by the Division in association with the Phase 1 bond <br />release will reflect the extent of facilities removal observed during the bond release inspection. <br />(2) Hillslope and drainage channel gradients and general design compliance--- <br />(3) Performance of the reconstructed topography. Symptoms of failures or instabilities such as slumping <br />or exposed highwalls will be examined--- <br />(4) Hillslope design function with regazd to erosion--- <br />(5) Swales and depressions with regard to numbers of such features and effect on post-mining land use--- <br />