_INSPECTION - C1980005 (35) - Laserfiche WebLink

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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. Postmine Channel PM-12A Vicinity Segments of Roads"F"and "C", in the northeast portion of the permit area run along the proposed permit boundary that would separate the proposed Sage Creek permit area from the area that would be retained as the Seneca II permit area. Other segments of the boundary would follow along the watershed divide between these two roads, while another segment of the boundary closely parallels postmining Channel PM-12A. The following observations were made during the inspection: • In association with the Sage Creek permit application, the proposed Sage Creek permit boundary through the current Seneca II permit area will need to be clearly marked on the ground, and surveyed for final mapping purposes. To the extent practicable, the boundary separating the two permit areas will need to be located such that disturbed ground within the Sage Creek Permit Area drains to Pond 004 or Pond 002, while disturbed ground within the (future reduced)Seneca II permit area drains to Pond 008. If there are limited small areas where it is not practicable to achieve this division of drainage, any such areas of untreated flow from one permit area to the other would need to be delineated and approved as small area exemptions, within the appropriate permit. • Remnant scraper road segments with rill erosion were evident at both the upper and lower ends of Channel PM-12A. These remnant road segments need to be properly scarified to obscure the road and eliminate rills, and reseeded. • The lower segment of PM-12A curves to the north, intersects and runs down the South Road light use road for a short distance, and then enters Channel PM-13 which runs along the east side of the road. PM-13 flows into Sediment Pond 008. This channel routing is as shown on Bond Release SL-4 maps. However, various approved permit maps that depict postmining topography and drainage locations, as well as runoff/sediment modeling (SEDCAD)designs in the approved permit indicate that the lower segment of PM-12A would curve to the south and merge with Channel PM-12, which drains into Sediment Pond 004. SCC will need to submit a technical revision application to revise the appropriate sections of the application, including postmine topography maps and SEDCAD design sections,to correctly reflect the drainage configuration that exists on the ground. The revision plan designs should include channel profile, cross sections, and liner specifications for the entire length of the PM-12A channel, including the segment along the South Road to the confluence with PM-13, incorporating an appropriate road dip channel crossing. • There is a topographic"saddle", which is the drainage divide between the Pond 004 watershed and the Pond 008 watershed, located along the South Road a short distance southwest of the point where PM- 12A intersects the road. On the reclaimed slope northeast of the saddle, there is a remnant scraper route, with minor rill erosion along its length, which runs diagonally across the slope from northeast to southwest. Drainage down the scraper route is directed to the general area of the saddle, and it is not clear whether flow would run south towards Pond 004 or north towards Pond 008 from that location. A series of small water bars will need to be constructed along the scraper route and at the lower end just above the saddle,to ensure that any flow from the slope that is intercepted by the scraper route would be directed into the PM-13 watershed, and ultimately,to Pond 008. 5