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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 /> General Comments <br /> This was an aerial inspection of the Seneca II-W Mine. The site was flown on the morning of 10/28/08, and <br /> Harry Ranney of the Division took 22 oblique and near vertical digital image photos. The images were viewed by <br /> Dan Mathews of the Division on 11/07/08. The images covered most portions of the mine disturbed areas. Site <br /> conditions appeared to be dry, although in a few locations there appeared to be a light dusting of snow or frost. <br /> Stock ponds T-20, T-18, T-5, T-26, T-27, and T-25 were observed; all except T-20 appeared to contain pooled <br /> water. Sediment Ponds 006, 016, 016A, and 017 were observed; all appeared to be full or nearly full, with no <br /> problems evident. <br /> Roads <br /> Road segments observed included most of the Ridgeline Access Road, Oil Well Access Road, the South <br /> Extension Light Use Road, fully reclaimed and reduced width sections of Road K, and portions of the reduced <br /> width sections of Road J. In general, the roads and reclaimed road segments appeared stable and well <br /> maintained. One exception is the slide damaged area along the Road J segment in the vicinity of Pond 016 and <br /> 016A, which appears largely as described in previous reports (refer to discussion under"Slides and Damage", <br /> below). <br /> Slides and Damage <br /> In a July 29, 2008 addendum to the 2008 Rill and Gully Repair Plan, the operator outlined a plan for geotechnical <br /> assessment and monitoring of the"Pond 016 Slide", along the segment of Road J adjacent to Pond 016, which <br /> was implemented in August(including installation of piezometers). <br /> In addition to the Pond 016 area slide along Road J (described above), there was renewed cracking and settling <br /> in spring 2008 immediatelyseXV the fenced shrub planting area up-slope from Pond 016. A evaluation plan <br /> to allow for assessment and development of remedial measures for the"shrub plot slide"was also included in <br /> the July 29, 2008 addendum. <br /> Although some grading to maintain the road through the"Pond 016 Slide"area has been performed, slide <br /> remediation is pending results of the geotechnical assessment. The extent of any grading in the vicinity of the <br /> "Shrub Plot Slide" could not be determined from the photos. <br /> The operator is asked to provide a written report by the end of 2008, addressing both the"Pond 016 <br /> Slide and the"Shrub Plot Slide". If a final report cannot be provided by 12/31/08, an interim report <br /> addressing the reasons for further extension,summary of results obtained to date, and a schedule for <br /> any further monitoring, as well as a deadline for submittal of a final report and implementation of the <br /> remedial plan should be submitted by that date. <br /> Hydrologic Balance <br /> Stock ponds T-25, T-26, and T-27 appear have been completed or largely completed during 2008. P.E. <br /> construction certifications will need to be provided for these ponds, and the ponds will need to be included in the <br /> quarterly pond inspection reports and future annual P.E. impoundment certification reports. One item of note is <br /> that it appears that T-25 embankment construction, topsoiling, and seeding has been completed, but the spillway <br /> outflow channel may not have been riprapped (although it is possible that riprap was obscured due to the photo <br /> angle). Permit Table 13-11A.3 specifies that the T-25 spillway outslope is to be lined with 12" D-50 riprap. Pond <br /> T-26 and T-27 specifications are for spillway outflow channel to be lined with 9" D-50 riprap. Photo angle and <br /> resolution did not allow for determination of riprap installation on the T-26 and T-27 spillway channels. Please <br /> ensure that the stock pond spillways are riprap lined in accordance with the approved plan. <br /> 3 <br />