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<br />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 />General Comments <br />This was a complete quarterly inspection of the mine site and office records. Records were checked at the <br />Seneca Mines main office on the afternoon of 11/27, and field inspection was conducted on the morning of <br />11/28, accompanied by Roy Karo of SCC. Site access was extremely limited due to heavy snowfall on the night <br />of 11/27, continuing on 11/28. Approximately 7 to 9 inches of snow had accumulated at Seneca II-W by gam <br />Tuesday morning. The combination of deep snow and the fact that a number of roads in the reclaimed area <br />have recently been reclaimed, and other roads reduced in width but not yet gravel surfaced, limited access to <br />many areas. The combination of snow cover and moderate to heavy snowfall that continued during the <br />inspection prevented detailed observations. Field inspection was restricted to limited observations that could be <br />made from along the Tie-Across Road, Mine Entrance Road, and the "loop route" extending from Road "A" and <br />along the Ridgeline Access Road through the 006 and 005 reclaimed area watersheds. <br />Availability of Records <br />Required records were on file and up-to-date. The Explosives Permit issued by the Bureau of Alcohol, Tobacco <br />Firearms and Explosives (ATFE) expired in July 2006. Roy Karo indicated that all explosives and storage <br />facilities have been removed from the II-W site. SCC has no plans for future storage of explosives at Seneca II- <br />W, but they would like to retain the option of storing explosives in the Yoast permit area in the future, and as <br />such, they have applied for a renewal of the ATFE Explosives Permit (which covered all three SCC permit <br />areas). I contacted ATFE field agent Marianna Mitchem in the Denver Field Office by phone on 11/29/06. She <br />stated that her September inspection had verified that no explosives were on site at II-W, and verified that SCC <br />had applied for renewal, which was in progress. She also indicated that ATFE had issued a "Letter of <br />Authorization" to SCC, to cover the interim period pending issuance of the renewal explosives permit. <br />Hydrologic Balance <br />Sediment Ponds 005 and 006 were the only sediment ponds that could be accessed. Both ponds appeared to <br />be functioning properly. Slushy ice film had formed on both ponds. 006 was discharging approximately 25 gpm <br />over the top of the spillway riser. 005 pool elevation was approximately 18" below the top of the riser; no <br />discharge. <br />Roy Karo stated that new Stock Ponds T-26 and T-27 in the 016 reclaimed watershed had been completed, but <br />that Stock Pond T-25, in the lower 017 reclaimed watershed did not get constructed (due primarily to wet <br />conditions that prevailed through much of the fall field season, and hampered reclamation operations). Over <br />2.5" of rain were recorded at the site each month during August, September, and October. <br />Backfill and Grading and Roads <br />Roy Karo indicated that Road "J" and "K" reclamation grading to reduced configuration had been completed, but <br />topsoiling of the reclaimed slopes and gravelling of the travel surfaces had not yet been completed. Due to <br />removal of the safety berms and lack of gravel surfacing, travel along the snow covered Road "J" would have <br />been hazardous, and was not attempted. The Ridgeline Access road was passable with four wheel drive, but <br />was slick and in one location we came close to getting stuck in the ditch. <br />Mr. Karo described various gully repairs and drainage improvement grading that had been completed since the <br />previous inspection, but due to the limited site access and snow cover, the grading work could not be checked. <br />Topsoil <br />Mr. Karo stated that wet conditions that prevailed during most of the fall field season impacted topsoiling <br />operations, and that significantly less acreage was topsoiled than had been projected earlier in the year. Due to <br />the ground conditions, heavy equipment operators were laid off for the season at the end of October. He <br />3 <br />