_INSPECTION - C1994082 ‎(41)‎

• Permit No: C1994082
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 7/15/2009
• Email Name: DTM
• Media Type: D
• Archive: No

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.
This was a Phase I bond release inspection of the Seneca Coal Company LLC (SCC) Yoast Mine,
conducted on July 15 through 17, 2009 by Dan Mathews, Sandy Brown and Marcia Talvitie of
the Division of Reclamation, Mining, and Safety(DRMS), and Howard Strand of the Office of
Surface Mining(OSM) Denver Office. Jennifer Maiolo, Erin Parks and Mark Lowry of the
Bureau of Land Management(BLM) Little Snake Field Office participated during the first day of
the inspection only. Roy Karo, Scott Belden, and Ryan Costa represented Seneca Coal Company
(SCC) on the inspection. Larry Kunckle of Craig met up with the group on the morning of July
15 on the property owned by John Patrick of Dubuque, Iowa, in the upper YPM 1-1 watershed, at
the south end of the reclaimed area. Mr. Patrick had made prior arrangements to have Mr.
Kunckle represent his interests at the bond release inspection, since a portion of the SL-2 release
area was on the Patrick property, but Mr. Patrick was unable to make the trip from Iowa to attend
the inspection. On July 16, inspection participants included only DRMS, OSM, and SCC
representatives. On July 17, participants were limited to Roy Karo of SCC and Dan Mathews of
DRMS. Inspection on the 17t'was limited to check of office records, sedimentation ponds, and
other topics not specifically related to the bond release evaluation. Weather conditions were
warm and clear during the inspection, and ground conditions were dry in most areas.
The inspection was conducted in response to a Phase I bond release application(SL-2 in the
DRMS filing system) for 515.8 reclaimed acres of the total 1019 acres of disturbance within the
Yoast permit area. The SL-2 application was determined to be administratively complete on
October 15, 2007, following receipt of newspaper proof of publication on October 5, 2007. The
SL-2 inspection was delayed initially due to the onset of winter conditions in late 2007, then
further delayed to allow for review and approval of Technical Revision No. 37 (TR-37), which
amended certain aspects of the reclamation plan pertinent to SL-2, notably permanent drainage
design details. The TR-37 proposed decision was issued on December 18, 2008.
The Yoast permit area includes a narrow access road corridor(former primary haul road)which
runs approximately 5 miles from Routt County Road 27 to the main body of the mine where coal
extraction occurred. Primary disturbances in the coal extraction portion of the permit area
include the North Pit and South Pit areas, connected by a narrow Neck Pit area. Pit backfilling
and grading has been completed in all areas, and topsoiling and revegetation has been completed
in most areas. A portion of the South Pit area in the lower Pond 012 watershed has been
impacted by a significant slope failure"the Pond 12 Slide". Slide remediation has not been
completed, and topsoiling and permanent drainage construction in and adjacent to the slide
affected area has been delayed. The Pond 012 slide and immediately adjacent areas were not
included in the SL-2 release request.
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