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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 />General Comments <br />This was a partial field inspection of the Seneca II-W Mine Site, conducted by Dan Mathews <br />of DMG, accompanied by Roy Karo, SCC Reclamation Manager. <br />Weather was clear and warm, and soils had dried considerably since the previous <br />inspection. Stockponds and sediment ponds remained full, or close to full, from spring <br />runoff and above average rainfall in June. <br />Roy Karo reported that SCC continues to anticipate that coal extraction will cease at Seneca <br />II-W by mid-December, 2005. Active coal extraction operations are now limited to the Wolf <br />Creek/Sage Creek pit area. Wadge area coal extraction has ceased, and the remaining <br />Wadge Pit areas are being closed and reclaimed. <br />Beginning July 9, union mine employees (all large equipment operators) were to be on <br />vacation for two weeks. During the vacation period, normal mining and reclamation <br />operations will be shut down. Equipment operators will be called in during the vacation <br />period only as needed on an emergency basis. Contract negotiations have been initiated <br />between Seneca management and the union. If agreement is not reached by September, <br />there is the possibility of a mine strike at the Seneca operations. <br />Roads <br />Mine roads were properly maintained and in good condition. Several segments of the <br />Ridgeline Access road have not yet been completed in accordance with the design approved <br />in TR-49. This road is to be completed during 2005. Substantial progress had been made <br />on the segment from the ridgeline to Haul Road "A" since the previous inspection, with <br />some minor grading, as well as surfacing, and some topsoiling and seeding of graded cut <br />and fill slopes still to be completed. Work was continuing on this segment at the time of <br />the inspection. The segment in the "D" Pit area has not yet been gravel surfaced, and <br />culvert installation has not yet been completed. PR-4 Stipulation 35 requires completion of <br />width reduction grading along the former "A" Road segment of the Ridgeline Road by 9.1_ <br />05. The entire Ridgeline Road is to be completed and the "G" Road is to be narrowed to <br />post-mine configuration in 2005. <br />Hydrologic Balance <br />Sediment control structures including sediment ponds, collection ditches, and topsoil <br />stockpile SAE sumps appeared in general to be properly maintained and functional. <br />Requested maintenance along the collection ditch segment up-gradient from Pond 017 had <br />been completed since the previous inspection. <br />