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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. General Comments This was a partial inspection of the Seneca II-W Mine, conducted by Dan Mathews of the DRMS Grand Junction Field Office. I was accompanied on the inspection by Dennis Bugay, of SCC, and discussed observations made during the inspection with Roy Karo, SCC Mine Manager, at the mine office following the site inspection. There has been much reclamation work completed recently in the 016 and 017 watersheds, in the South Extension of the permit area. Mr. Bugay indicated that scraper operations had been completed for the season earlier in October, and that all large scale topsoiling operations had been completed. Weather conditions were cold and blustery, with brief snow/rain/sleet flurries. There was light snow cover on the ground from snowfall overnight, and ground conditions were muddy from rain that fell prior to the snow. Ground conditions made vehicle access to recently reclaimed areas of the 017 and upper 016 watersheds, and the ridgeline in the South Mine area impossible, and walking was difficult due to slick, muddy conditions. The dragline was still in place where it has been stored for several months, at the intersection of HRD"A" and the Ridgeline Access Road. Cattle which had been turned onto portions of the older reclamation in September (and noted in the September aerial inspection) had been moved off the mine earlier in October. Roads The permanent postmine Ridgeline Road was traveled, from the north entrance gate at the County Road junction (former Haul Road "G"), along its entire length up through the "D", "C", and upper "A" pit reclamation, to its end point at the "A" Road Junction. The road is gravel surfaced, and was in good condition, despite muddy site conditions and several intense rain storms during late summer/early fall. A section of the road ditch near Pond 005 that had previously eroded had been repaired and lined with turf reinforcement mat earlier in the summer, and the lined ditch segment has held up well. Seeded perennial grasses and big sagebrush have established very well on the roadsides along the lower segments of the road between the "D" Pit and the County Road. All backfill and grading work associated with South Area road reduction ("J", "L", and lower "K") and road elimination (upper "K", "H", and "I") has been completed. Topsoiling and seeding has been largely completed along these segments. However, the regraded/topsoiled Road "J" was re-disturbed earlier in the fall due to MSHA requirement that a safety berm be restored along the road until equipment operations in the South Mine area were completed. Operator had recently begun to regrade the topsoil berm back over the road fill, to restore the final reclamation configuration. Upon completion of berm elimination, the remaining narrowed travel surface will be re-gravelled, and the roadside and fill will be re-seeded. Seeding will also be required along various steep upper cut slope areas along the "J" and "K" roads, which could not be drill seeded due to the slope gradient. These steep areas will be roughened by track-hoe gouging or dozer cross-ripping, as soon as soils have dried sufficiently, and after roughening they will be broadcast seeded. Operator is planning to accomplish as much of the broadcast seeding as possible by aerial seeding with fixed wing aircraft, during the week of October 29-November 2. Road ditches in several locations along "J" Road were blocked by temporary crossings installed in the ditches to allow access to topsoil stockpiles. The topsoil stockpile areas have recently been reclaimed. The temporary ditch crossing fill material needs to be promptly removed to restore design ditch configuration. 3