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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during the <br />inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br />evidence supporting the enforcement action. <br />This was a partial inspection of the Seneca II Mine conducted on August 12, 2003 by Mike <br />Bouiay of the DMG. Lori Smith of Seneca Coal Company (SCC) was present during the entire <br />inspection. Weather conditions were hot and sunny. Topsoil redistribution and discing was <br />underway in the Wadge East Pit area at the time of the inspection. <br />HvdroloQic Balance <br />In accordance with permit conditions and established timeframes, construction of all post mine <br />drainage channels should be completed by the end of August 2003. Final construction has not <br />been completed at the following Post Mine Channels: portions of PM-1 and PM-4, the lower <br />portion of PM-6, all of PM-8, PM-12, and PM-13. PM-8 has been graded and shaped but has not <br />been lined or rip rapped. Please complete all Post Mine channel construction in accordance with <br />the approved reclamation schedule as shown on Exktibit 13-2, Backfill and Grading Schedule. <br />Topsoil, Rev~etation, and General Mine Plan Compliance <br />Notice of Violation CV-2003-005 was issued on June 17, 2003 for failure to comply with permit <br />conditions, and for failure to conduct topsoil redistribution and seeding according to the <br />reclamation schedule and established timeframes. Significant erosion was noted during the June <br />2003 inspection along a portion of Road Fl, located west of Stock Pond T-30. Good progess <br />has been made at the Road Fl location. Ditches have been re-worked, road drainage runouts <br />have been built and significant work has been completed at the site of the erosion that occurred <br />along Road Fl. As discussed in the inspection report issued June 17, 2003, runoff from Road Fl <br />has impacted a revegetated area adjacent to Post Mine Channel PM-4. This area has not been <br />repaired and is considered part of the abatement for NOV CV-2003-005. Please repair the <br />erosion that has occurred in the revegetated azea above PM-4 between Stock Ponds T-30 and T- <br />28 by the abatement deadline, September 15, 2003. <br />Topsoil redistribution and seeding was to be completed at the Road F1 location and three other <br />locations in the Wadge East Pit area and Wolf Creek Pit areas by 11/02. Topsoil redistribution <br />and seeding has been completed at one of these locations located adjacent to Post Mine Channel <br />PM-5. Required work has not been completed at two additional locations, one is the topsoil pile <br />located north of Road F 1 in the former Wolf Creek Pit and the other is the eastern end of the <br />Wadge East Pit azea north of Pond 008. Topsoil redistribution and seeding should be completed <br />at these locations no later than the abatement deadline of September 15, 2003. <br />