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tlt. COMMENTS -COMPLIANCE <br />Below are comments on the Inspection. The comments include discussion of observafions <br />made during the inspection. Comments also describe any enforcement actions taken during <br />the Inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection of the Seneca II mine site. The weather was clear and warm. Roy Karo <br />accompanied me on the entire inspection. <br />Seneca Coal Company is expecting to submit a Phase I bond release application early next year that <br />will cover the entire mine site including pre-, interim and post-law reclamation as determined by the <br />date the Surface Mining Control and Reclamation Act passed, August 3, 1977. <br />As part of this inspection we looked at some of the pre-law and interim reclaimed lands in the northern <br />part of the permit area. From what I could see from the two-track access, the lower areas took good <br />with a dense vegetative cover. What appears to be the final pit in the upper Wolf Creek area, the land <br />has been regraded into a 'horseshoe bowl' topography with a pond in the lower area that drains to the <br />north. Standing water in the pond was serving as a water source for cattle. A remnant fenced <br />revegetation research plot is evident on the east side just above the pond. The slopes on the eastem <br />and southern portions are poorly vegetated and eroded where the WoN Creek spoil serves as the <br />growth medium. Several large erosion gullies are visible on the steep eastem slope that drains into <br />the pond. Wolf Creek overburden spoiled into the drainage to the north and to the south is also poorly <br />vegetated. The Wolf Creek spoil is acidic and is not conducive to vegetative growth. At this point, it is <br />questionable whether these Wolf Creek areas will be eligible for bond release. Seneca may want to <br />consider submitting two separate bond release applications to avoid confusion between the pre-law <br />and interim reclaimed areas, and the post-law areas. <br />Reclamation in the 'post' law areas is progressing very well. A couple areas remain where erosion is <br />being monitored,-but for the majority of the reclaimed lands, the site is stabilized and well vegetated. <br />The spillways on Ponds 4 and 8 have been redone and the ponds look good. Most of the haul roads <br />have been narrowed to their final configuration. The northern part of the main haul road to the south <br />remains to be narrowed. <br />The first year of vegetation sampling was conducted over the majority of the reclaimed area this past <br />July. Although considerable discussion has occurted regarding the revegetation sampling process, <br />and revegetation standards, Seneca has yet to submit a revision to the permit addressing these <br />issues. This technical revision must be submitted as soon as possible. <br />I walked the upper segment of post mine drainage channel PM-4. Some erosion was observed in the <br />upper reaches, buf overall the drainage is functioning well. An open soil pit was observed near the top <br />of the channel (on the north side) that should be filled. Several patches of Canadian thistle were <br />observed. Stock ponds, along this drainage look good, with a number of cattle using T30. <br />I also walked PM-23 that drains into the Pecoco pond. A hole was observed in the channel a couple <br />of years ago, presumably along the old highwall. It is still there and it needs to be filled and stabilized. <br />Approximately 800 cattle were brought in to graze the reclaimed lands following the vegetation <br />sampling. They were scattered throughout the reclaimed area, but congregating near the ponds. <br />Both the sediment ponds and the permanent stockponds were being utilized. <br />A weed spraying crew will return to Seneca II for fall spraying. Numerous patches of Canadian thistle <br />and houndstongue are the target species. <br />