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III. COMMENTS -COMPLIANCE <br />Below aze 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 />This was a partial inspection and a Phase I bond release inspection of a portion of the <br />Yoast Mine conducted on October 4, 2006 by Mike Boulay of the Division of <br />Reclamation, Mining, and Safety (DBMS). Ms. Jennifer Maiolo of the Bureau of Land <br />Management (BLM) from the Craig, Colorado office accompanied the DBMS for a <br />portion of the inspection during the morning of October 4a'. Mr. Roy Karo of Seneca <br />Coal Company (SCC) accompanied the DBMS for the entire inspection. Weather <br />conditions were cloudy and cool. It did not rain during the inspection, but ground <br />conditions were damp from recent rainfall prior to the inspection. The entire Phase I <br />bond release azea was accessible. There was no other activity at the mine site during this <br />inspection. <br />The total permit area at the Yoast Mine encompasses 2,318.3 acres. The primary focus of <br />this inspection was a Phase I bond release request of 188.1 reclaimed acres located within <br />an area referred to as the North Pit. This Phase I bond release inspection was conducted <br />pursuant to SCC's Phase I Bond Release Application (SL-Ol) submitted July 28, 2006. <br />During the inspection, participants walked through the majority of the North Pit azea <br />subject to the bond release request, to allow for visual assessment of compliance with <br />pertinent requirements, including backfilling and grading, site stability, blending of <br />regraded land to undisturbed areas, and drainage control. Post-Mining Topography and <br />Drainage (Exhibit C), Post Mine Cross-Sections, and As-Built Drainage Profiles were <br />included in the bond release application and reviewed by the DBMS during the technical <br />evaluation of the bond release application. <br />Roads <br />One light-use road is located in the bond release request azea and is shown on Exhibit 12- <br />l, Operations Plan in the permit application package (PAP). Light-use roads aze <br />discussed on pages 29 through 31 of Tab 13 in the PAP. Atypical light-use road cross- <br />section is given on Figure 13-6. SCC has indicated to the DBMS that they would like to <br />retain the light-use road in the North Pit as permanent because it is needed for monitoring <br />and the postmining land use. The lower portion of the light-use road is shown in <br />Photograph No. 1. SCC has not specifically designated this road or any other roads at the <br />Yoast Mine as permanent. SCC should request permanent retention of this road and <br />update the PAP to include an as-built profile to demonstrate compliance with Rule <br />4.03.3(3) and a landowner request in writing that the road be left open for further use in <br />accordance with Rule 2.05.5(1)(6). <br />The possibility of changing the light-use road location and grade were discussed during <br />the Phase I inspection due to the likelihood that portions of the road in its present <br />