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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 an aerial inspection of portions of the active operations area and reclamation areas at Seneca II- <br />W. The flight was on the morning of 7/20/05. Harry Ranney of DMG obtained 12 oblique and near- <br />vertical digital images. The images were viewed by Dan Mathews of DMG on 8-1-05. Site conditions <br />appeared to be relatively dry in most locations, although sediment ponds and stock ponds all contained <br />water. <br />The Dragline was operating in the Sage Creek/Wolf Creek mining block, and a coal shovel was operating <br />in the pit. <br />Roads <br />There were no evident problems associated with permit area roads. Grading work associated with the <br />new segment of the Ridgeline Road in the upper "A" Pit area has been largely completed. Width <br />reduction grading of the former HRD-A segment has been largely completed, and the cut and fill slopes <br />have been topsoiled. Seedbed preparation and seeding of the cuts and fills has not yet been initiated. <br />Hydrologic Balance <br />Sediment ponds covered by the images included Ponds 006, 016, 076A, and 077. All of the ponds <br />appeared to be full of water or nearly so. Embankments appeared to be intact and stable, and it <br />appeared that disturbed runoff from the designated pond collection areas was being properly routed and <br />settled in the ponds. Pond 016A in-slope slide repair areas appear to have remained stable. Water was <br />pooled in each of the stock pands constructed on the reclaimed areas (T-18 on upper 005 Gulch in "C" <br />Pit, T-20 on lower 005 Gulch in "D" Pit, and T-5 on upper 006 Gulch in the "A" Pit). <br />Required permanent drainages in the "D" Pit (005-E11, "C" Pit (005 Gulch), "B" Pit (006-NE1, 006-NE4), <br />and "A" Pit (006 Gulch, 006-NE2, 006-E1, 006-S1, and 006-SE1) within the original permit area have all <br />been constructed. The network and pattern of permanent drainage channel construction in the original <br />permit area portion of the reclaimed area appears to be in general conformance with the approved plan. <br />There are areas of minor erosional scour on lower segments of several of the recently constructed <br />drainages, where grading and riprap replacement will be warranted, including 006 Gulch, 006-NE1, and <br />006-NE2, and possibly other locations. Three riprap lined permanent drainages were also recently <br />constructed in the regraded Ridgeline Pit area of the South Extension, including Channel PM-4, and two <br />additional channels. <br />Backfill and Gradin <br />Backfilling and grading operations have been completed in the ridgeline Wadge Pit Area at the north end of the <br />South Extension, as well as at the far south end of the south leg Wadge Pits, in the Pond 016 watershed. Final <br />grading has also been completed within substantial portions of the north leg Wadge Pits in the Pond 16 <br />watershed, and largely completed within the entirety of the Wadge Pit area in the Pond 17 watershed. The <br />upper portion of the PM-3 Channel in the north leg Wadge Area has been roughly formed. Wadge Pit backfill <br />and grading operations are ahead of the currently approved grading schedule. Backfill and grading operations in <br />the Wolf Creek mining block are contemporaneous with active pit operations. Backfilling and grading was <br />previously completed in the original permit area portions of the "A", "B", "C" and "D" Pits. <br />3 <br />