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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 a partial inspection of the Seneca II-W Mine, accompanied by Roy Karo, SCC Reclamation Manager. <br /> The Tie Across Haul Road was inspected on the afternoon of 5/26, other portions of the mine were inspected on <br /> 5/28 and the morning of 5/29. Weather was cloudy with intermittent light rain on 5/26, clear and mild on 5/28 <br /> and 5/29. Due to rains over the weekend on top of soils that were at high moisture levels from snowmelt, <br /> conditions remained muddy at higher elevations and some locations were still not accessible by vehicle at the <br /> end of the week. It appeared that high intensity rainfall had occurred in some locations, most notably in the Pond <br /> 016 watershed of the South Mine area,where lower segments of the permanent stream channels were heavily <br /> eroded and extensive repairs will be required. <br /> The mine has been largely reclaimed, with the exception of the shop area and entrance road. Large scale <br /> drainage maintenance, slide repair, and weed control are on-going activities. <br /> Roads <br /> The Tie Across Haul Road, Mine Entrance Haul Road, Haul Road "A", Haul Road "J", Haul Road "K", and the <br /> Ridgeline Access Road were open and were driven. The Ridgeline Light Use Road was impassable south of <br /> Culvert PM-10, which prevented access to upper portions of the 016 and 017 watersheds in the South Mine <br /> Area. Seasonal maintenance has recently been initiated in various locations along the roads, and is continuing. <br /> The following specific concerns were noted: <br /> • Roy Karo pointed out a couple gullied relief drain ditches on either side of a large fill along the Tie <br /> Across Road, that were not visible from the vehicle. The location is known as"Coffee Break Hill", and <br /> the erosion is mentioned in a notation on the 2009 Rill and Gully survey map. The more severe erosion <br /> is on the north side of the road. This location had eroded in years past, shortly after the road was <br /> constructed, and the ditch was subsequently lined with large riprap. The original rilprap has washed out <br /> and new erosion has resulted (see Photo#9). Repair and stabilization of the ditches on both sides <br /> of the road is required. <br /> • On the Ridgeline Road approximately 120'west of the Pond 005 embankment, concentrated flow had <br /> resulted in a short gully up to 1 foot deep on the road embankment. Repair is necessary; riprap or <br /> TRM installation appears to be warranted. Gully is marked on 2009 R&G survey map. <br /> Further up the Ridgeline Road, minor rilling was observed along a reclaimed topsoil stockpile access <br /> road, and concentrated flow from this location had resulted in a gully on the road outslope.Stabilization <br /> measures both up-slope from the travel surface and on the fill slope are warranted. This location <br /> is marked on the 2009 R&G map. <br /> • Significant rilling was noted to the north side of the travel surface along the Ridgeline Road between <br /> Stock Pond T-22 and the reclaimed "D" Pit spoils, with a gully on the north side of the fill slope at the <br /> curve just up the road from the stock pond. The gully is marked for repair on the 2009 R&G Map; <br /> interseeding may be warranted along the side of the road. <br /> • A drop structure installation is needed on the channel near the brush-line below Culvert A-5 on <br /> the Ridgeline Access Road,to stabilize head-cut erosion. This is marked on the 2009 R&G Map. <br /> • The T-2 and T-3 sediment check ponds along Road "A", south of the shop area, were both full of water <br /> and appeared to be functioning properly. TRM inlet channels to the check ponds appeared to be <br /> functioning well. The check ponds will likely need to be excavated to clean out accumulated <br /> sediment later this spring/summer. <br /> 3 <br />