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'~ SENECA II 12/93 page 2 Seneca II has an excess spoil disposal fill, the Wolf Creek fill, and the latest certified report was done 8/5/87. This was the last time any material was put in the fill. DMG interprets the inspection requirements, at 4.09.1(11)(a), as only requiring quarterly inspections when material is being added to the fill (other than those time periods specified). A road embankment fill on one of the haul roads is required to be inspected annually by PWCC. The last report was dated 6/10/93. All haul roads are certified. DMG would not necessarily require PWCC to certify all of the haul roads because the Colorado Rule at 4.03.1 (1)(d) only requires certifications on haul roads "not within the disturbed area". This is less stringent than the Federal regulations, but DMG is currently rewriting the road regulations as a result of a 732 letter. The liability insurance is with the Insurance Company of America, CGO G1 658513-0, for the period 10/1/93 through 10/1/94. There is one pond on the permit area, the Spring Creek stock pond, that receives disturbed area drainage and is not designed or certified by PWCC. The pond was constructed prior to PWCC mining the area. Discharges from this pond pass through a PWCC certified sedimentation pond. DMG's interpretation of the definition of impoundment eliminates this structure from regulation (at 1.04(64)). The definition includes, "...which is built to or does in fact retain water, sediment, or _ slurried waste in suoaort of minino and reclamation oaerations..." DMG pu~orts that the pond does not support mining operatioris, therefore, it is not a structure subject to the Colorado program. Sometime between the first and second day of the inspection, a grader damaged a CMP at the junction of roads E5A and E6A. PWCC was working on the end of this CMP to repair it, so a violation was not required. No Notices of Violation or Ten-Day Notices were issued as a result of this inspection.