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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. Commentrst also describe any enforcement actions taken during the inspection <br />and ~hev~r~cft~uo~heileros~onsa~g~ig [{tne9roaededif~FiesmPlindt~it~ona~'grading and drainage construction <br />will be necessary when conditions dry out, to achieve compliance with the approved design <br />and to fully implement Abatement Item 1. Extensive ditch re-grading and riprap installation <br />will be necessary along the road ditches and down-drains, when site conditions allow, to <br />implement Abatement Item 2. <br />Availability of Records <br />Records were checked in the Seneca Mine office on March 19. In general, required records <br />were on file and up to date through the 4`" quarter, 2002. A few items that require <br />attention were discussed with Dennis Jones on March 19, and/or Bob Shevling on April <br />16/17. These items include: <br />1) Annual certification of impoundments, pursuant to Rule 4.05.9(14). Relatively new <br />provisions of this rule require Professional Engineer (P.E.) inspection of all impoundments on <br />an annual basis, and certification by the P.E. that each impoundment has been constructed <br />and/or maintained as designed, and in accordance with the approved plan and the applicable <br />regulations. The operator has indicated that the initial annual certifications will be <br />completed for each impoundment, no later than the end of the 3r° quarter, 2003. This <br />schedule is acceptable to the Division. <br />2) Initial construction certification was on file for Pond 006, Phase III design. Review of <br />permit information seems to indicate that Phase IV construction has been completed, but <br />construction certification for Phase IV could not be found. Operator will need to promptly <br />provide the Phase IV certification to the Division, and place the certification on file if the <br />construction certification was previously conducted, or will need to promptly schedule such <br />inspection and provide the certification to the Division prior to the end of the 2n° quarter, <br />2003. <br />3) Sediment Pond 017 construction was recently completed, but P.E. inspection and <br />certification has not yet been completed. Pond 017 P.E. certification will need to be <br />provided prior to the end of the 2n0 quarter, 2003. <br />4) Various haul road certifications were on file within the permit documents, but no access <br />road certifications could be found. Such certifications (or relevant showing demonstrations <br />in lieu of certification) pursuant to Rule 4.03.2(1)(f)(i) and (ii) would be necessary only for <br />designated access roads "not within the disturbed area in accordance with 4.05.2(4)". <br />From review of permit text and maps (page 13-28 and Exhibit 13-11.81, it appears that the <br />only designated access road that would require certification or relevant showing is the road <br />segment near the eastern end of the Tie Across Haul Road that provides access to the <br />"Savage Shop". Operator will need to ensure that the required access road certification or <br />relevant showing for this access road segment is submitted to the Division and placed on <br />file, by the end of the 2ntl quarter, 2003. <br />Roads <br />Frequently used roads in most areas were wet from snow the previous couple of days, but <br />were being regularly maintained to facilitate travel and proper drainage. Steep temporary <br />5 <br />