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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made during the <br />inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br />evidence supporting the enforcement action. <br />General Comments <br />This was a complete quarterly inspection of the Seneca II-W Mine Site and office records, <br />conducted by Dan Mathews of DMG. In addition, a joint OSM/DMG Contemporaneous <br />Reclamation Special Focus inspection was conducted on the first day of the inspection. <br />Henry Austin of OSM participated in the Special Focus portion of the inspection. Roy Karo, <br />SCC Reclamation Manager, was present during both the Special Focus inspection on 5/24, <br />and during remaining field inspection and records review on 5/25. <br />Weather was clear and mild on both days. Soils were moist in most areas due to recent <br />snow melt. Stockponds and sediment ponds were full or close to full, and there was some <br />water pooled in depressions where snow had drifted. <br />Contemporaneous Reclamation Evaluation <br />Pertinent documentation was reviewed in the mine office prior to the on-site inspection, <br />including the approved backfilling and grading schedule map, Exhibit 19-1A, and the <br />Reclamation Map from the 2004 Annual Reclamation Report. When Permit Revision 4 iPR- <br />4) was approved in November 2004, over two miles of final cut Wadge pits had been left <br />open, under an approved variance from the t80 day rough backfilling requirement pursuant <br />to Rule 2.05.4i2)(c). The Wadge pits had been left open across the entire lengoved under <br />South Area Permit Extension, to accommodate highwall mining operations app <br />PR-4. The Division's reclamation cost estimate for PR-4, assumed that the "worst case <br />disturbance" would occur in 2005, and was based on the two miles plus of open final cut <br />Wadge pits, plus active mining with up to 4 spoil ridges in the Wolf Creek/Sage Creek <br />Mining Area. A 59.7 million bond was submitted, based on .this worst case reclamation <br />cost assessment. <br />Subsequently, Seneca Coal Company (SCC) made a decision to not conduct highwall mining <br />of the Wadge, and backfilling of the Wadge pits was initiated in January 2005. Based on <br />the earlier than anticipated initiation of pit backfilling, the extent of open pits and volume of <br />material to be moved is now significantly less than was assumed for the bond calculation. <br />During the site in"spection, observation confirmed that backfilling and grading progress was <br />well ahead of the approved schedule. The Wadge "D" Pit area, in the northern portion of <br />the original permit area, had been previously final graded, and remaining topsoiling and <br />seeding in that area was completed in 2004. Wadge "A" and "B" pit areas within the <br />central and southern portions of the original permit area, had 2002, 2003, and 2004 backfill <br />and grading deadlines. These areas had been fully graded, and permanent channels had <br />been constructed. All graded areas within the "original permit" boundary had been <br />topsoiled, with the exception of a small east draining Swale area along the eastern ridgeline <br />near the south boundary of the "original permit" area. The Swale area had been too wet to <br />topsoil until recently, but topsoiling was in progress in this area during the inspection. <br />Approximately 270 acres were topsoiled during 2004 and 235 acres seeded during the <br />