_INSPECTION - C1980005 ‎(34)‎

• Permit No: C1980005
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 7/15/2008
• Email Name: DTM
• 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.
Introduction and Overview
This was a Phase II bond release inspection of the Seneca II Mine, covering approximately 1793.5 acres of
reclaimed land within the permit area, as delineated on map Exhibit A(Seneca 11 Phase li Bond Release Area),
of the May 2008 Phase II Bond Release Request application submitted by Seneca Coal Company(SCC). The
inspection was conducted July15 through July 17, 2008 by Dan Mathews of the Division of Reclamation, Mining,
and Safety(DRMS), assisted by DRMS GIS intern Brian Grady. Other inspection participants included Roy Karo
and Vern Pfannenstiel representing SCC, and three representatives from the Bureau of Land Management
(BLM) Little Snake Field Office in Craig; Jennifer Mayolo, Shawn Wiser, and Roy Mckinstry. Weather conditions
were warm and clear, with no measurable precipitation during the inspection; ground conditions were dry and
roads were dusty due to dry conditions that had prevailed in the area since early June. Dan Mathews and Roy
Karo were present during the entire inspection, while other participants were present for only portions of the
inspection. BLM representatives departed prior to noon on the first day. Vern Pfannenstiel was present only
during the first day of the inspection, and Brian Grady departed following the second day.
The Phase II Bond Release Application (SL-3), was determined to be Complete on June 18, 2008, following
receipt of newspaper Proof of Publication of Availability of the application. The areas proposed in the application
for Phase II bond release include Bond Release Blocks 1, 2, and 3(BR131, BRB2, and BRB3), depicted on map
Exhibit B (Seneca 11 Phase 11 Bond Release Chronological Revegetation). Each of the defined bond release
blocks were reclaimed subsequent to enactment of the federal Surface Mining Reclamation Act(SMCRA) in
August 1977. BRB1 (revegetated 1977 through 1981)was reclaimed prior to approval of SCC's initial State of
Colorado Permanent Program permit, and as such, is subject to somewhat less stringent quantitative
revegetation success standards than BRB2(revegetated 1982 through 1995)and BRB3(revegetated 1997
through 2003). All of the reclaimed areas included in the three bond release blocks were subject to topsoil
salvage and replacement requirements, and were seeded with diverse seedmixes to serve the postmine land
use needs. Seedmixes evolved over time to include a higher percentage of native species, with significant
reduction in the component of aggressive introduced grasses. Each of the separate bond release blocks,
defined by color shadings on Exhibit B, contain numerous delineated revegetation parcels, with the date of initial
permanent seeding listed for each designated parcel. The entire acreage included in the Phase II release
application was previously approved for Phase I release in the Division's decision on Bond Release Application
No 1 (SL-1), which became final on February 22, 2007.
Over the course of the three day inspection, virtually all areas included in the release application were viewed
either by stops at vantage points along the various permanent roads (frequently combined with relatively short
jaunts from the road stop to view a particular feature or area of interest more closely), or by relatively long"cross
country" hikes to view areas that were more distant from or not visible from the roads. The basic inspection plan
was to focus on the older reclamation parcels of BRB2 during the first day of the inspection, all of BRB4 and
portions of BRB3 on the 2"d day, and remaining portions of BR133(the largest block)on the P day. With some
exceptions, this schedule was followed. Numerous digital photographs were taken to document site conditions
and observations (see Attachment 1 to this report). In addition, numerous locations of interest or concern were
marked using a Trimble GeoXT GPS unit(see Attachment 2 to this report). Due to logistics, GPS data was
collected only on the first and second day of the inspection, which is why no features of interest are recorded on
the GPS map within the PM-10 drainage or other BRB-3 parcels in the southwest portion of the release request
area.
Within the Phase II bond release application area, there are a number of haul roads that have been reduced for
the postmining use, light use roads that have been retained for postmining use, and sediment ponds and stock
ponds that have been retained for the postmining use. These designated features that have been approved as
permanent structures were closely inspected for compliance in SLA (see the Division's December 27, 2006
Phase I Bond Release Proposed Decision and Findings of Compliance document), and are depicted on Permit
Map Exhibit 13-2A, Postmining Topography and Permanent Features. The approved permanent features were
checked during the SL-3 inspection, and appeared to be functioning properly, with only minor maintenance
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