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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 partial inspection of the Seneca II Mine conducted on June 23, 2005 by Mike Boulay <br />of the DMG. Roy Karo of Seneca Coal Company (SCC) was present during the entire <br />inspection. Weather conditions started off to be sunny and warm but it rained intermittently <br />toward the end of the inspection at some locations of the mine site. Ground conditions were <br />mostly dry. There was no activity at the mine site during the inspection. <br />Roads <br />Retention of permanent roads was addressed in Item 1 of the Division's Midterm Permit Review ~ <br />dated August 17, 2004. Stipulation 32 remains in effect and requires a detailed reclamation plan <br />in accordance with Rules 2.05.4(2) and 4.03 for road modification and retention. The current <br />requirement on page 13-55 of the PAP states that permanent roads will be narrowed to twenty <br />feet for post-mining use. Narrowing of the roads is a prudent plan, consistent with the approved <br />post-mine land use. Reduction of the roads will ensure long-term drainage stability, reduce <br />erosion and maintenance requirements, and will enhance the likelihood of successful bond <br />release. <br />SCC submitted Technical Revision No. 37 in response to the Division's Midterm Review, which <br />presented changes to the approved road-narrowing plan. Four former haul roads, one light-use <br />road and one pre-law road located within the permit boundary are proposed as permanent roads. <br />SCC is not proposing any modifications to the pre-law road. The Division is currently reviewing <br />the proposed road retention plan submitted in TR-37. Proposed permanent roads were the focus <br />of this partial inspection and each of the former haul roads and light-use road were inspected to <br />determine present condition and width. Pictures of the former haul roads and proposed light-use <br />road aze included in this inspection report. <br />Road E1 is well maintained with no significant erosion problems noted. Road ditches were <br />maintained and clear of sediment or debris. There was no flowing water in any of the road <br />ditches at the time of the inspection. Road widths were measured at nine locations along this <br />road. Widths measured from ditch to ditch on either side of the road ranged from 29 feet to a <br />maximum of 60 feet. The top surface or working surface of the road ranged from 20 feet to 45 <br />feet wide. The widest portion of the road was located at Culvert 19A. Culvert 19A is 100 feet in <br />length beneath the road surface. <br />Road C accesses the top of the Wolf Creek Pit area and was measured at two locations. The top <br />surface of the road ranged from 16 feet to 21 feet wide. This road is in good condition and <br />stable. Just above the junction with Road F and Road E1 the road measured 21 feet across from <br />ditch to ditch. The former radio tower location at the top of this road has been fully reclaimed. <br />