_INSPECTION - C1982057 (33) - Laserfiche WebLink

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X 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. inspectors at designated locations. Inspectors discussed observations and concerns with the operator representatives following each walkabout. With only a few exceptions, the entire length of each reclaimed drainage channel was walked. Permit area roads subject to the release request were driven and observed,with stops at various locations. Field slope measurements were not taken during the inspection, however extensive inclinometer measurements and channel dimension measurements had been taken along all of the North Area reclaimed drainages during DRMS site inspections of October 6 through October 7, 2005 (report dated 10/12/05), and June 29 through June 30, 2006 (report dated July 21, 2006). Data from these reports was reviewed in the context of the SL-2 evaluation. Permanent channel profile and reclaimed area cross-section "As Built" certified drawings were reviewed and compared to permit designs and and pre-mine cross-sections. Observations made during the field inspection and determinations made during subsequent compliance evaluation are presented in the narrative of this report. Permit area maps showing disturbance areas, SL-2 release request areas, and DRMS proposed approval and exclusion areas, are included as Figure 1 and Figure 2, attached to this report. Supporting photographs are provided in Attachment 1. Attachment 1 includes ground photos taken by both inspectors during the site inspection on 10/14/09 through 10/16/09, as well as aerial photos taken by Harry Ranney of DRMS on 10/15/09. Relevant documentation developed over the past several years is included in previous inspection reports and also referenced in this report as appropriate. Roads Summary Status of Permit Area Proposed Permanent Roads A number of existing roads within the permit area have been approved or proposed as permanent structures for the postmining land use, to allow for access through the permit area by multiple private landowners, and to provide access to various portions of the permit area to facilitate postmining use and management. Haul roads or haul road segments to be retained for permanent retention as access roads are modified for postmining use by eliminating MSHA berms, reducing travel width to 28 feet(Routt County Road 53C) or 20 feet(all other permanent access roads), and grading and seeding roadsides and graded slopes. Several light use roads have been proposed for permanent retention as ranch roads, in most cases to replace ranch road segments that were in place on the landscape prior to mining. Description and status of roads proposed for permanent retention is provided in Attachment 20-2 (Seneca II-W Mine Permanent Structures Documentation) of the approved permit application package. 3