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i�• 'i <br /> III. COMMENTS-COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made during the <br /> inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br /> evidence supporting the enforcement action. <br /> This was a Phase I bond release inspection of the Seneca I1 Mine conducted on July 14, 2009 by <br /> Dan Mathews of the Division of Reclamation, Mining, and Safety(DRMS). Howard Strand of <br /> the Office of Surface Mining(OSM) Denver Office, and Jennifer Maiolo of the Bureau of Land <br /> Management (BLM) Little Snake Field Office also participated in the inspection. Roy Karo, <br /> Scott Belden, and Ryan Costa represented Seneca Coal Company(SCC) on the inspection. <br /> Frank and Ed Camilleti (grazing lessees on portions of the permit area)were present for the <br /> initial overview discussion of the planned inspection at the SCC mine office,but they did not <br /> accompany the group during the field inspection. Weather conditions were warm and clear <br /> during the inspection, and ground conditions were dry in most areas. <br /> The inspection was conducted in response to a Phase I bond release application(SL-4 in the <br /> DRMS filing system) for 135.3 reclaimed acres of the total 2,295.3 acres of disturbance. The <br /> SL-4 application was determined to be administratively complete on December 1, 2008. The <br /> major portion(1,793.5 acres) of the entire disturbed area was previously approved for Phase I <br /> release in association with SL-I, in 2006. The SL-4 application requests release for a 125.8 acre <br /> block of reclamation in the southeast portion of the permit area referred to as the"East Wadge <br /> Area", along with 8 acres of reclaimed solid waste disposal site in the southwest portion of the <br /> permit area, and a 1.5 acre corridor associated with new postmining drainage channel PM-12A, <br /> located approximately mid-way between the solid waste disposal area and the East Wadge Area. <br /> The East Wadge Area is characterized by long, relatively steep slopes, and was excluded from <br /> the Division's SL-1 approval due to extensive erosion. The PM-12A channel was constructed <br /> along a former scraper route that had eroded. The channel had not been completed at the time <br /> the SL-1 application was submitted, and was therefore not included in the SL-1 application. <br /> Likewise, the 8 acre portion of the Solid Waste disposal site had not yet been regraded at the time <br /> the SL-1 application was submitted, and was not included in that release application. <br /> Following a brief overview meeting at the mine office, the field inspection was initiated. Frank <br /> and Ed Camilleti chose not to take part in the inspection, and departed following the overview <br /> meeting. During the inspection, participants walked through large portions of the release request <br /> area, to allow for visual assessment of compliance with pertinent requirements, including <br /> backfilling and grading, site stability,blending of regraded land to undisturbed areas, and <br /> drainage control. An inclinometer was used to field check gradients at major drainage channels <br /> and selected slope locations. Relevant documentation developed over the past several years is <br /> included in previous inspection reports and referenced in this report as appropriate. <br /> 1 <br />