2008-04-22_INSPECTION - C1980005

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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 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 channel PM-1 to the large permanent impoundment, Pond 002, as well as down the channel which runs along Road E to CMP 15A. Snow cover remained on roads throughout much of the mine area, with muddy conditions prevalent in locations where snow has only very recently melted off. This effectively limited access to only small portions of the mine area, specifically the shop area and Road E up to within '/ mile approximately of the Pecoco Pond. 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. Quarterly Discharge Monitoring Reorts for CDPS Permit CO-0000221 (Seneca Mine Complex) for the 1St Quarter 2008 were hand delivered to me during the inspection. The report showed no exceedances of applicable effluent limits during the 1St Quarter. Roads Only a few road travel surfaces have been maintained through the winter, as noted in the "General Comments" above. The Haul Road E surface was passable and in good condition at the time of the inspection up to a point beyond Culvert 15A, where snow drifts and muddy conditions prevented further vehicle access. Hydrologic Balance snowmelt at the site has recently begun in earnest, and permanent drainages that we were able to access were carrying significant volumes of runoff. Much snow still remains in the permit area, particularly at upper elevations and on north and east facing slopes. South facing slopes (and west facing slopes at low elevations) were largely snow free. Due to limited access, detailed inspection was limited to the shop facilities area and locations visible from the lower segment of Road E. No problems were evident within the areas viewed from Road E. At the shop area, there were scattered items of trash and debris (plastic bags, plywood panels, cardboard, etc.), along and adjacent to the perimeter collection ditch to the shop area sediment pond (Pond 003). The trash and debris needs to be cleaned up. There was flow in the Pond 003 collection ditch, and no evidence that the ditch had been overtopped. However, there were locations along the ditch where build up of the ditch berm is warranted, to provide freeboard consistent with the remainder of the ditch. Ditch maintenance will be necessary as soon as ground conditions allow. Pond 003 embankment appeared stable, and the pond was discharging clear water. The wash bay supply pond in the shop area was eliminated by embankment removal late last fall, as it was no longer needed. Further reclamation work in the immediate vicinity of the pond site will be warranted when ground conditions allow. Small area exemption silt fencing in various locations around the perimeter of the graveled yard area across the road from the shop were damaged by snow accumulation over the winter. The silt fence segments need to be replaced or repaired as necessary. 3