INSPEC43035

• Permit No: C1982057
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 4/27/2004
• Media Type: D
• Archive: No

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.
This was a complete inspection of the Seneca II-W Mine for the 2n0 Quarter 2004,
conducted by Dan Mathews of the DMG Grand Junction Field Office. Roy Karo,
Reclamation Manager for Seneca Coal Company (SCC), was present during the inspection.
Field inspection was initiated the morning of Apri{ 27 and concluded the evening of April
29. Office records were checked on the morning of April 30. Weather during the
inspection was clear and mild, in contrast to the previous week, in which the mine area had
received significant precipitation (mixed rain and snow). It was very windy on the 28`".
Primary snowmelt in the mine area had occurred in early April. All areas were free of snow
and accessible, but there were still muddy conditions in low areas, and there was some
flow in most of the larger ephemeral drainages in the permit area, including the primary
reclaimed watersheds.
The dragline was still operating in the north block of the Wolf Creek/Sage Creek mining
area, in the southern extension of the permit area, as it has been for several months. The
lower split of the Wolf Creek Seam was being exposed by the dragline at the time of the
inspection, with coal loading and hauling operations following closely behind the dragline
operation. At the upper end of the Wolf Creek block near the eastern ridgeline, operations
are closely approaching the limit of stripped topsoil, and topsoil stripping operations had
recently been reinitiated.
"D" Pit Native Drainage Channel Assessment
The condition of the native drainage channel reach between the "D" Pit regraded areas and
the roadside stock tank (T-22) just upstream from Haul Road Culvert G5 was evaluated
during the inspection, and numerous photos were taken. The channel runs through areas of
unstable surface geology, and there is evidence of past channel incision and bank sloughing.
The channel segment was previously checked on September 25, 2003, to document the
condition of the channel. The following excerpt is from the Division's September 30, 2003
inspection report.
Th/s channel system conveys disturbed runoff from the D"Pit area, but is
otherwise undisturbed by mining activities. For over a decade, peak f/ows through
this segment of channel were minimized due to the capture of runoff by mine pits
and/or diversion of flow via road ditches. The mine pies were backfilled and graded
in 2002, and road ditch diversions were eliminated after the 2003 spring
runoff... The Division concluded that it would be prudent to document the existing
condition of the channe% and we have requested the operator to submit a plan to
minimize the potential for excessive erosion of the channel reach that might occur
during the early years of reclamation, before the reclaimed watershed is fully
stabilized by vegetation.
The operator chose not to implement temporary diversions or other measures, due in part to
the extensive drainage modifications that would have been required to divert a significant
quantity of runoff from the reclaimed portion of the watershed. The operator concluded
that reclamation work completed in 2003, including topsoiling, drainage channels, and stock