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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 />This was a complete inspection of the Seneca II Mine conducted on November 15, 2001 by Mike <br />Boulay of the DMG. Robert Shevling of Seneca Coal Company (SCC) was present during the <br />inspection. Weather conditions were sunny and warm. Ground conditions were dry throughout <br />the mine site. A dozer was working at the postmine drainage channel location PM-1. This was <br />the only activity at the site during this inspection. <br />Hydroloeic Balance <br />Constmction of several postmine drainage channels remains to be completed at the Seneca II <br />Mine site. These include PM-1, 4, 5, 6, 8, 12, 13, 16, and 20. Construction of PM-1 was in <br />inspected. The channel has been graded to its final configuration, a liner has been placed in the <br />upper portion of the channel and riprap was being hauled and placed in the channel bottom. The <br />fabric liner at the PIv1-I location was noted to be folded under in some locations or not properly <br />keyed in along all edges. As discussed during previous inspections and during the final <br />permitting of the postmine drainage and topography design, use of fabric liners under riprap can <br />be problematic if not installed properly. If used, fabrics must be properly keyed to avoid <br />undermining of the installation. Additionally, the fabric and entire channel cross section must be <br />covered with the appropriate rock thickness, with no gaps in the rock along the channel. <br />It was specifically noted during this inspection that at the entrance to PM-1, the liner was not <br />keyed in properly. Please take steps necessary to ensure that fabric liners at all postmine <br />drainage channel locations are keyed at channel entrance and exit locations, and along all edges <br />to avoid erosion below the fabric. <br />Postmine Drainage Channel PM-4 was also inspected. Rills 1-2 feet deep aze forming at the head <br />of this channel in the revegetated slope above the channel inlet. The fabric liner has been <br />damaged and partially deteriorated at the entrance to this channel. Please replace and properly <br />key in the fabric liner at the entrance to PM-4 and repair the rills that have formed in this azea. <br />As noted in the previous inspection (see Inspection Report dated 10/25/01), sediment removed <br />from the channel bottom of Postmine Drainage Channel PM-6 had been stockpiled across PM-6 <br />at the upstream side of the Road E1 Dry Stream Crossing. As requested, the stockpiled sediment <br />has been removed from the PM-6 channel and the channel bottom has been graded in prepazation <br />for riprap placement. <br />