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III. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. General Comments This was an aerial inspection of portions of the active operations area and reclamation areas at Seneca II- W. The flight was on the afternoon of 4-15-05. Harry Ranney of DMG obtained 38 oblique and near- vertical digital images. The images were viewed by Dan Mathews of DMG on 5-3-05. At higher elevations in the permit area, most disturbed area locations exhibited significant snow cover on north facing slopes, with other locations appearing muddy but largely snow-free. Lower elevations were largely snow free, with only scattered remnant snow patches on north facing slopes. Sediment ponds and stock ponds were ice-free and appeared to be full or nearly full, from snow-melt runoff. The Dragline was operating in the Sage Creek/Wolf Creek mining block, and coal loading operations were in progress in the active pit area. Roads The Ridgeline Access road has been roughly completed across the topsoiled/seeded "D" Pit Area, from the upper end of Haul Road "G", to the eastern ridgeline. Culvert PM-4 at the 005 Gulch Crossing was installed in 2004. The road surface appears to be quite muddy, and there appear to be rills along segments of the road, although details are difficult to discern. When conditions dry sufficiently, it appears that grading and gravel surfacing of this road segment will be necessary. Road "G" ditch outlet drains between the upper end of the haul road and Culvert G5 appeared to have held up well. These locations experienced erosion due to runoff in recent years, but subsequent grading and riprap installation appears to have been effective. Stock Tank T-22, which functions primarily to slow runoff and trap sediment above Culvert G5, was nearly full of water, but did not appear to be discharging. Hvdrolooic Balance Sediment ponds covered by the images included Ponds 005, 006, 016, 016A, and 017. All of the ponds appeared to be full of water or nearly so. Embankments appeared to be intact and stable, and it appeared that disturbed runoff from the designated pond collection areas was being properly routed and settled in the ponds. The entire length of the southern perimeter of the Wadge disturbed area up-gradient from Pond 17 was not captured on the images, so it could not be determined whether maintenance of the collection ditch along this segment had been completed since the previous inspection. This area will need to be ground checked, and collection ditch maintenance performed as previously indicated as soon as ground conditions allow. Pond 016A in-slope slide repair areas appear to have remained stable. It could not be determined whether requested inlet riprap repairs below the large culvert outfall at the northeast corner of the pond had been properly repaired. This area will need to be ground checked, to confirm that necessary repairs have been completed, Stock Tanks T-18 (upper 005 Gulch), T-20 (lower 005 Gulch), and T-5 (upper 006 Gulch) have been constructed on reclaimed areas. All of these ponds were full of water or nearly so. The network and pattern of permanent drainage channel construction in the original permit area portion of the reclaimed area appears to be in general conformance with the approved plan. Riprap installation appears to have been completed on the steeper channel segments as warranted, although 3