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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 inspection of portions of the disturbed areas at the Seneca IIW Mine, <br />conducted in the accompaniment of Bob Shevling of Seneca Coal Company (SCC). <br />Inspection was conducted on July 30 and 31s`, beginning at approximately gam each day. <br />Weather was clear and warm on the 30`", partly cloudy and warm on the 315'. Focus of the <br />inspection was on the following issues: <br />1) Reclamation progress relative to approved reclamation schedule and <br />contemporaneous reclamation requirements (addressed in this report under the <br />Backfilling and Grading topic); <br />2) Extent of rills and gullies and need for repairs pursuant to the approved rill and gully <br />plan (addressed in this report under the Backfi//ing and Grading topic); <br />3) Apparent revegetation success in selected areas; and, <br />4) Presence of noxious weeds and implementation of approved weed control plan. <br />Additional backfilling and grading work had been conducted in lower portions of the "A" Pit <br />area since the previous inspection, Sediment Pond 016A had been substantially completed, <br />and construction work was progressing on Haul Road K. Site conditions were dry, although <br />there had been a light rainfall the day prior to the inspection. <br />Records <br />The status of certain records that had been requested during the previous inspection was <br />checked. Referenced records include the construction certification for Sediment Pond 17 <br />(pond construction completed in the fall of 2002), construction certification for the Access <br />Road from TAHR to the "Savage Shop", and required designs or appropriate "typical <br />design" for stock pond impoundments constructed on the reclaimed area or other disturbed <br />areas. <br />These documents were not available at the mine office. Bob Shevling explained that they <br />had been forwarded to Montgomery Watson, permitting consultant to SCC, for <br />incorporation in a permit revision application (PR-4) currently under preparation. The <br />requested records need to be provided to DMG no later than August 8, 2003. <br />The operator is reminded that a request for waiver from the quarterly inspection <br />requirements of 4.05.9117) may be submitted along with the design information for the <br />stock ponds, pursuant to 4.05.9(18). In addition, the operator is reminded that required <br />annual P.E. certifications for impoundments, including all stockponds, are to be submitted <br />to DMG no later than September 30, 2003. <br />