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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 field inspection of the Seneca II-W Mine Site, conducted by Dan Mathews of DMG. Sandy Brown from the DMG Denver office was present during the entire inspection, along with Roy Karo, SCC Reclamation Manager. Bob Postle, of the OSM- WRCC office in Denver was also present during a portion of the inspection (in a non- inspector capacity). Weather was cool and overcast with drizzle and rain showers; ground conditions were muddy. The spring of 2005 has been unusually wet; Roy Karo reported that the mine site received approximately 3 inches of rain the previous weekend. Stockponds and sediment ponds were full or close to full, and water pooled in depressions in various locations. Muddy conditions limited access to some areas, and travel by vehicle and foot was difficult. Roy Karo reported that SCC anticipates coal extraction will cease at Seneca II-W by mid- December, 2005. Roads Active use haul roads were properly maintained and in good condition. Light use roads were muddy, and in some cases not passable as a result. Several segments of the Ridgeline Access road have not yet been completed in accordance with the design approved in TR- 49. This road is to be completed during 2005. The segment from the ridgeline to Haul Road "A" had been "roughed in" since the previous inspection, and. culvert installation was in progress. The segment in the "D" Pit area has not yet been gravel surfaced. PR-4 Stipulation 35 requires completion of width reduction grading along the former "A" Road segment of the Ridgeline Road by 9-1-05. "G" Road is also to be narrowed to post-mine configuration in 2005. Hvdrolooic Balance Sediment control structures including sediment ponds, collection ditches, and topsoil stockpile SAE sumps appeared in general to be properly maintained and functional. Recent sediment deposition was noted along the collection ditch segment that extends from the lower end of the southern-most Wadge Pit disturbed area down to Sediment Pond 017. This ditch segment will need to be maintained as soon as conditions allow. Pond 005 water level was a few inches below top of primary riser; no discharge. Pond 006 was spilling over top of primary riser; clear discharge, approximately 30 gpm.