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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 />General Comments <br />This was a complete quarterly inspection of the Seneca II-W Mine. I was accompanied on the inspection by Roy <br />Karo, Seneca Coal Company Mine Manager. Weather was clear and warm. Ground conditions were dry; on <br />most areas of upland reclamation, dominant grasses were largely dormant due to the relatively hot, dry growing <br />season to date. Large scale reclamation operations were recently initiated for the season at II-W; scraper fleet <br />and other heavy equipment were recently moved from Yoast Mine to Seneca II-W. Site inspection was <br />conducted on July 30 and 31~~, office records were checked on August 1. <br />NOV CV-2007-002 Abatement. Modification, and Extension <br />Abatement Step 1 was previously completed within the specified time frame, and verified during inspection of <br />May 30, 2007. Abatement Step 2 (submittal of a technical revision plan for drainage modifications), was abated <br />by submittal of TR-60 on 6/26/07. Abatement Step 3 was abated by completion of damage repair grading and <br />seeding, and by completion of drainage modifications (ditch enlargement and berm construction) in accordance <br />with the abatement plan in TR-60. Proper abatement of Step 3 was verified during inspection on 7-30-07, and <br />the NOV was terminated on 8/1/07. An approvable TR-60 drainage plan was viewed at the mine site during the <br />inspection, and TR-60 proposed approval decision was issued on August 2, 2007. An original and one copy of <br />SCC's final adequacy response letter to TR-60, with properly updated Figure 20-1.2, was hand delivered to me <br />at the mine site on August 1, 2007. <br />Availability of Records <br />Records were on file and up to date through the Second quarter 2007, at the mine office. <br />Roads <br />Active use roads and permanently reclaimed roads to be retained for the postmining land use {those for which <br />width reduction grading and gravel surfacing have been completed) were generally in good condition. Significant <br />road reclamation work is continuing this field season (including complete reclamation of roads to be eliminated, <br />and width reduction/stabilization/gravel surfacing of roads to be retained for the postmine land use. "J" road <br />reduction grading has been largely finished, but final gravel surfacing, as well as topsoiling and seeding of cut <br />and fill of slopes is yet to be completed. Grading, topsoiling, and seeding is still to be completed along upper <br />segments of "K" road (to be fully eliminated) and lower segments of "K" Road (to be reduced in width and <br />retained for the postmining land use). "J"and "K" Road reclamation is scheduled to be completed this year. <br />Final reclamation grading/downsizing of Haul Road "A" and the Mine Entrance Haul Road is also scheduled <br />under the approved permit for 2007 (see permit Exhibit 19-1 ). Operator has indicated this schedule may not be <br />practicable, pending Peabody's determination regarding future use of the dragline, and the need to maintain the <br />full haul road width if a decision is made to walk the dragline off-site, from its present location at the junction of <br />Road "A" and the Ridgeline Road. Q minor revision to the reclamation schedule will need to be submitted <br />shortly, including a revised Exhibit 19-1, addressing any modifications to the approved regrading <br />schedule, if delays are warranted. <br />The operator indicated that the first stage of reclamation would be implemented on Haul Road "A" and the Mine <br />Entrance Haul Road within the next month. This will involve grading to eliminate the MSHA berm along the <br />outside edge of the roadway, beginning at the upper end of Haul Road "A", and continuing down to the lower end <br />of the Mine Entrance Haul Road. This will eliminate concentrated flow along the inside of the berm, and the <br />resultant rilling and gravel deposition at outlet points. Stabilization seeding of the areas disturbed by berm <br />elimination will be warranted if there is any significant delay between berm elimination and final road <br />width reduction grading. <br />3 <br />