_INSPECTION - C1982057 (60) - Laserfiche WebLink

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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 a complete inspection of the Seneca II-W Mine, conducted by Dan Mathews of the DRMS Grand Junction office, accompanied by Roy Karo, Seneca Coal Company(SCC) Mine Manager. Weather was clear and warm. Major snowmelt runoff has recently begun at the minesite, and there was significant flow down permanent channels 006-NE1 and 006 Gulch, and down the Haul Road "A" ditch to Culvert A-3. Significant snow cover still remains throughout much of the mine area, with muddy conditions prevalent in locations where snow has only very recently melted off. The only passable roads at this time are the Tie Across Haul Road, the Mine Entrance Haul Road, Haul Road "A" up to the dragline, and the oil well access road. Other roads remain drifted over and impassable, limiting access to most areas of the mine. As noted in the previous report, this winter's heavy snow cover will benefit recent seedings and plantings, but will also increase the potential for erosion and slope instability, particularly on steep slopes below areas of major drift accumulation. Availability of Records Records were checked at the mine office, and were found to be complete and up-to-date through the 1st quarter, 2008. Roads Only a few road travel surfaces have been maintained through the winter, as noted in the"General Comments" above. The Mine Entrance Road and Haul Road "A" surfaces (up to the dragline location at the intersection of HRD-A and the Ridgeline Access Road)were passable and generally in good condition at the time of the inspection. There was heavy sediment laden snow melt flow down the HRD-A ditch to Culvert A-3. Culvert A-3 discharges down a short segment of rock lined channel into sediment check/Stock Pond T-2. The stock pond was functioning properly, but was filling in with sediment and will require cleanout following completion of snow melt. The riprapped channel from the Culvert A-3 outlet down to the pond will also require maintenance. Due to the heavy snowpack and associated runoff this year, it is anticipated that there will need to be extensive maintenance of road drainage ditches, culverts, and check ponds following snowmelt. Hydrologic Balance Sediment Pond 006 was the only sediment pond that could be accessed. The pond was approximately half open, half covered over with slushy ice. There was heavy inflow of sediment laden runoff into the pond, primarily from 006 Gulch. The pond was discharging over the top of the spillway riser; the flow volume out the primary spillway outlet filled approximately half the 24" pipe(see Photo#3834). The discharge water was cloudy, and I obtained a sample for TSS/SS analysis (Sample#057-006-1605). The sample was taken using a 1-liter untreated plastic sample bottle at 4:05 pm, and immediately placed in an iced cooler, which I kept in my possession until I delivered the sample to Grand Junction Labs at approximately 9:15 am on 4/25/08. Lab staff stated that the settleable solids analysis would be run that morning, prior to expiration of the 48 hour holding time. The Seneca CDPS discharge permit includes a snowmelt exemption from the Total Suspended Solids standard, so in this instance, settleable solids is the applicable sedimentation standard (0.5 ml/1). Quarterly Discharge Monitoring Reports for CDPS Permit CO-0000221 (Seneca Mine Complex)for the Vt Quarter 2008 were hand delivered to me during the inspection. The report showed no exceedances of applicable effluent limits during the 1s'Quarter. As noted previously, snowmelt at the site has recently begun in earnest, and permanent drainages in the"A" and "B" pit reclamation areas were carrying significant volumes of sediment laden flow. Much snow still remains in 3