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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 complete quarterly inspection of the Seneca II Mine, including check of office records. The various <br /> mine roads were travelled and large areas of the reclamation was viewed from the vehicle. Sediment ponds and <br /> various areas of interest were accessed by foot. Significant portions of the East Wadge reclaimed area (not yet <br /> approved for Phase 1 bond release), as well as the acid spoil remediation area in the portion of the pre-law area <br /> that is still under bond, were walked. Weather was clear and warm, soils were moist from recent rains. Access <br /> was limited on 5/26 due to muddy road sections in certain locations, but by late morning on 5/27, all areas were <br /> accessible. The operation appeared to be in compliance with applicable regulatory and permit requirements. <br /> Inspector was accompanied by Roy Karo, SCC Reclamation Manager. <br /> The mine has been largely reclaimed, with remaining tasks limited primarily to future reclamation of the shop <br /> facilities area. <br /> Availability of Records <br /> Records were checked in the mine office on the morning of 5/29, and were found to be in good order and up to <br /> date. See Records Form attached. <br /> Roads <br /> Permit area roads were muddy in some locations on 5/26, but by 5/27 all roads were passable and generally in <br /> good condition, with typical seasonal maintenance warranted in some locations. Roads E, E1, C, F, the Pre-Law <br /> Road, and the Light Use Road were driven during the inspection. A segment of the Road F drainage ditch in <br /> the PM-4 vicinity was scoured and needs maintenance. <br /> Hydrologic Balance <br /> Sediment Ponds 002 (Wadge Impoundment), 003 (Shop Pond), 004, and 008, as well as the Pecoco <br /> Impoundment were observed during the inspection. All of the ponds were discharging clear flow, with no <br /> problems evident. The reclaimed area stock ponds observed all contained water from snowmelt and recent <br /> rains, as did the small pond in the portion of the Pre-Law area that has not yet been released from bond. <br /> Disturbed area runoff appeared to be properly contained within the approved sediment control system in all <br /> areas observed. Scattered debris was still present along the shop area containment ditch as noted in the <br /> previous inspection, and needs to be picked up and properly disposed of. <br /> Support Facilities <br /> A geotechnical assessment drilling program associated with facility site investigations for Peabody Sage Creek <br /> Coal Company's (PSCCC) planned Sage Creek Mine, within the Seneca II permit boundary, was recently <br /> approved within Minor Revision No. 60 (MR-60). The drilling plan was also approved as an amendment to an <br /> exploration Notice of Intent, held by PSCCC. The geotechnical drilling will entail up to 30 shallow drill holes within <br /> a 20 acre site in the Pond 002 watershed, immediately to the northeast of existing NO[ drill site#CCU036. The <br /> geotechnical drilling activities have not yet been initiated. <br /> There was no activity in the shop facility area. Due to financial problems, the company that had been using the <br /> facilities for fabrication and parts warehousing under a purchase agreement with Seneca, has ceased <br /> operations. <br /> 3 <br />