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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 a partial inspection of Roadside Mine, focusing on reclamation projects currently in progress at the CRDA and RSRDA refuse azeas. Inspection was conducted on 2/20/02 with no opemtor contact present. A brief follow-up inspection was conducted the afternoon of 2/21/02, accompanied by operator representative Jim Stover. Weather was cloudy and surface soils were moist from recent precipitation. 2/20/02 12SRDA Inspection began at gam at the South Portal facility area. A couple piles of debris still remain on top of the RSRDA refuse pile (one metal scrap and one mostly wood scrap), as well as a couple piles of metal scrap in the lower yazd area, as described in previous inspection. The 6" sail cover had been pushed off the upper portion of the RSRDA outslope, and construction of the approved terrace drains had been initiated. A scraper and small dozer were working on the terrace construction at [he time of the inspection. It was noted that the road to the soil borrow azea for the RSRDA project had recently been bladed, although soil excavation has not yet been initiated. The borrow azea boundaries will need to be cleazly marked in the field, and additional soil sampling pursuant to permit requirements will need to be conducted prior to initiation of excavation. CRDA-2 Topsoiling was in progress at CRDA-2. 3 trucks were being loaded by track-hce from Topsoil Pile #2, and were hauling to the top of CRDA-2, where soil was dumped and spread bydozer on the upper bench outslope, over previously spread non-toxic cover. Cover soiling had been completed andtopsoiling was near completion by 2121. Cover material had been obtained primarily from Coal Creek permanent diversion excavation, with lesser amounts from Cameo Borrow Area No. 1, and CRDA-2 Upper Diversion construction. Opemtor indicated that analyses from samples of the cover soil were on file at the mine office. Operator stated that all but one or two samples of re-spread subsoil had met permit specified quality requirements, and that in those areas some re-grading had been undertaken to achieve adequate blending as addressed in the permit. Soi] analyses will be reviewed by DMG during the next complete inspection. Upon completion of cover soil and topsoil placement on the refuse piles, DMG will conduct verification soil depth checks and quality samples. It was noted in the field that active soil placement areas had been staked to guide equipment operators in replacing required soil thickness. The CBA-1 borrow azea had been graded following completion of soil borrow, and the sediment containment ditch had been re-established. The small area that was re-disturbed will need to be[opsoiled and seeded. Substantial progress had been made on construction of the new CRDA-2 Upper Diversion. Extension of the channel wings at either end to the naturaldrainages outside the sediment containment system had not yet been completed, nor had finalriprap installation. Detailed inspection of the ditch was not made, because construction is still in progress, but some general observations were made. Riprap in most areas appeared to well exceed design requirements, however in some segments the ditch lacked awell defined channel, and riprap placement was such that flow in the ditch would not be confined to theripmp. Some segments appeared to be flat, or possibly reverse-grade; operator needs to ensure that the 2.5% design