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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 />This was partial inspection of the Seneca II-W Mine, conducted by Dan Mathews of the DMG Grand Junction <br />Field Office. This report includes review of 5-18-06 aerial imagery, as well as on-site observations made during <br />field inspection on 5-26-06. The site was flown by Harry Ranney of DMG on 5/18/06, and 21 oblique and near <br />vertical digital images were taken. The images were viewed on 5-30-06. <br />5-18-06 Aerial Images <br />Imagery covered most portions of the mine site, including active reclamation areas in the Wolf Creek final pit and <br />adjacent areas in the 016 watershed, graded and topsoifed areas in the 017 watershed, and recently seeded and <br />older reclamation areas of the "A", "B", "C", and "D" pit areas. On 5/18, reclaimed areas were free of snow with <br />the exception of one small remnant drift on a north facing slope at the far south end of the Wolf Creek mine <br />block reclaimed area. There were also some remnant drifts along the crest of the steep slope immediately to the <br />east of the ridgeline that defines the eastern perimeter of the mine area. All of the remnant snow had melted <br />prior to the inspection of 5126. <br />The various stock ponds and sediment ponds covered by imagery all appeared to be full or nearly so. <br />Dragline was still located at the lower end of the Wolf Creek final pit area, and appeared to be nearing <br />completion of the final pit backfilling. Grading is still to be completed in portions of the Wolf Creek block, lower <br />end of the South Leg and North Leg Wadge pits in the 016 watershed, Road H, and Road I and adjacent areas <br />in North Leg Wadge Pit vicinity. Final drainage channel construction will need to be completed in various South <br />Area reclamation blocks. This work, along with topsoiling and seeding of the graded areas is scheduled to be <br />completed during 2006. <br />There was evidence of recent (spring 2006) drill seeding on a small area that had been topsoifed but not seeded <br />in fall 2005, at the south end of the south leg Wadge Pit reclamation area in the 016 watershed. Areas seeded <br />in the fall of 2005 had just begun to "green up" in some areas, likely due to germination of annual cover crop <br />included with the permanent seedmix. Areas seeded in previous years exhibit more prominent vegetative cover, <br />with density and uniformity of cover generally increasing with age of reclamation. <br />Rill and gully erosion was evident in some locations on recently reclaimed hillslopes and drainage channel <br />locations; and repairs will be necessary in various areas. Areas of apparent erosion include vicinity of PM <br />Channel 5B in the large Neck Pit aspen plot, swale feature and scraper route in topsoifed area of North Leg <br />Wadge Pit, and slopes of Wolf Creek block reclamation seeded last fall. There are no doubt other areas where <br />erosion repair will be warranted, that were not covered or not visible in the imagery, given the large acreage of <br />new reclamation and the heavier than normal snowpack. Some rill repairs appeared to have already been <br />initiated, but it was obvious that other areas were not yet accessible due to muddy conditions. A number of <br />shallow puddles from recent snowmelt were evident in depressions and low areas. <br />There was an area of apparent seepage evident on a reclaimed "A" Pit slope southwest of the junction of <br />Permanent Channel 006 and 006-S1; there was no evidence of a slump or significant erosion associated with <br />the seepage. SCC had notified the Division of a slide located immediately east of the reclaimed Neck Pit area <br />on April 21; this slide location was not covered by the aerial imagery but was observed during the site inspection <br />on 5/26. <br />3 <br />