INSPEC23827

• Permit No: C1982057
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 7/30/2003
• Media Type: D
• Archive: No

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.
Mr. Shevling stated that he believed SCC would be able to complete backfilling and grading
of the lower variance area and the small section of upper "A" Pit variance area not included
in the PR-4 highwall mining proposal, if plans came together as envisioned. Factors Mr.
Shevling mentioned that would impact SCC's ability to comply with the schedule for the
remaining "A" Pit areas were the review timeframe associated with the PMT technical
revision, and scheduling associated with approved highwall mining at SCC's nearby Yoast
Mine. Apparently, the highwall miner machine is scheduled to be delivered and initiate
operation at Yoast in October. Due to the anticipated shift in coal production from surface
extraction to highwall mining, 9 dozer shifts normally assigned to assist surface pit
operations could be re-assigned to reclamation grading when highwall mining operations
begin at Yoast. Potential pitfalls would appear to include extended review timeframe
associated with the PMT technical revision, as well as delay in delivery or activation of the
highwall miner, or production of the highwall miner not meeting projections.
There is a small section of "B" Pit in the vicinity of the lower end of the "A" Pit, from which
a small quantity of coal has not been recovered. Recovery of the remaining "B" Pit coal is
to be accomplished within the next couple months, and backfilling and grading of the
remaining "B" Pit is to be completed during 2003, under the approved permit.
Sections of several designed permanent drainage channels in the "A" and "B" Pit
reclamation areas have not been constructed, and cannot be constructed until backfilling
and grading is completed within the respective portions of the Pond 006 watershed. These
drainages include, from north to south, the lower segment of Channel 006-NE1, Sections of
006 Gulch and its primary tributaries, and 006-SE1. As previously described, topsoil
replacement and drainage channel construction are to be replaced within 1 year of
completion of backfilling and grading. Assuming that spoil grading is completed within the
remaining Contemporaneous Reclamation Variance areas of the "A" Pit, and within the
remaining portion of the "B" Pit by the end of 2003, then topsoiling, permanent seeding,
and final channel construction would be required within the subject areas by November
2004.
Portions of the "A" Pit variance area that were regraded in 2002 lapproximately 60 acres;
see 2002 Annual Reclamation Report Reclamation Map) will need to ba topsoiled and/or
permanent seeded by November 15, 2003. Seedbed roughening will be required on slopes
25% and steeper.
In summary, there is a very significant amount of reclamation grading, topsoiling, drainage
construction, and revegetation to be conducted under the approved permit within the
remainder of 2003 and into 2004, including the described contemporaneous reclamation
variance areas discussed here above, and contemporaneous reclamation associated with on-
going pit operations. Compliance with permit specified time frames is complicated by
revision applications the operator plans to submit, requesting a timeframe extension to allow
highwall mining in the ridgeline Area "A" Wadge Pit, and proposing modifications to PMT
and drainage designs in the lower "A" and "B" Pit areas. Further, from the operator's
perspective, the ability to meet approved reclamation time frames at Seneca IIW may be
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