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~ay~ ~ of ~~ <br />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 combined complete inspection and a Phase I bond release inspection of the Seneca II <br />Mine conducted on August 7 through August 11, 2006 by Mike Boulay and Sandra Brown of the <br />Division of Reclamation, Mining, and Safety (DBMS). Mr. Henry Austin of OSMRE-DFD <br />accompanied the DBMS during the majority of the inspection, excluding azeas of the site that <br />were mined during pre-law or interim law timeframes. Mr. Roy Kazo of Seneca Coal Company <br />(SCC) accompanied the DBMS during the inspection of pre-law and interim law lands on August <br />11, 2006. Weather conditions were warm and mostly cleaz with no measurable precipitation <br />during the inspection. Ground conditions were dry. Cattle were being grazed at several fenced <br />pasture locations. <br />The primary focus of this inspection was a Phase I bond release request of 2,247.7 reclaimed <br />acres of its tota12,299.3 acres of disturbance. This Phase I bond release inspection was <br />conducted pursuant to Seneca Coal Company's Phase I Bond Release Application (SL-Ol) <br />submitted May 24, 2006. Almost all of the entire disturbed azea is being requested for Phase I <br />release. Excluded by SCC from this SL-01 bond release aze the Shop & Facilities including the <br />diesel storage azea, old and new bone yards, Solid Waste Disposal Area, and the former access <br />road that will now become the location of Post-Mine Channe] PM-12A. <br />During the inspection, participants walked through large portions of the site subject to the bond <br />release request, to allow for visual assessment of compliance with pertinent requirements, <br />including backfilling and grading, site stability, blending of regraded land to undisturbed azeas, <br />and drainage control. An inclinometer was used to field check gradients at major drainage <br />channels and slopes at permanent road locations where as-built cross-sections and road profiles <br />had been prepazed by SCC. A GPS unit was used to verify location of permanent features and to <br />record field data relevant to specific site locations. Relevant documentation developed over the <br />past several yeazs is included in previous inspection reports and referenced in this report as <br />appropriate. In addition, Post-Mining Topography (Exhibit E}, Cross-Sections of Backfilled and <br />Graded Areas, and As-Built Drainage Profiles were included in the bond release application and <br />reviewed by the DBMS during the technical evaluation of the bond release application. <br />Many of the proposed permanent structures including roads, sediment ponds, and Post-Mine <br />Channel PM-1 evaluated during this inspection aze pending final approval of Technical Revision <br />No. 37 (TR-37). The following documentation is pending approval of TR-37: Post-Mining <br />Topography and Permanent Features Map, Permanent Road Pro61es and Cross-Sections, As- <br />Built Certifications for all Sediment Ponds and the As-Built Certification for Post-Mine Channel <br />PM-1. The post-mine topography has not changed since approval of Exhibit 12-9 Post-mine <br />Contour Map with TR-36 (approved January 2005) and therefore, Exhibit 12-9 was used for . <br />