_INSPECTION - C1982057 ‎(33)‎

• Permit No: C1982057
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 10/14/2009
• 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.
former Haul Road "H" corridor extends to the southeast. The northern segment of reduced width
Road"J" is shown in Photo SL2-41. The road has been down-sized to postmine configuration,
with berms eliminated and roadsides and slopes revegetated. Haul Road"A" extends to the west
from this intersection, and leads to the mine shop facility area and eventually to the Mine
Entrance Haul Road, which provides access into the southern portion of the original permit area
(former"A" and "B"Pit area), from Routt County Road 53. The dragline is currently being
stored in the immediate vicinity of the major intersection, and the intersection area was not
included in the SL-2 release request area for this reason. Road"A" and the Mine Entrance Road
have been proposed as permanent access roads by SCC,but they have not yet been reduced to
permanent access road specifications, and they were properly not included by SCC in the
proposed SL-2 release request area. As-Built documentation for the reduced Road J has not
yet been submitted for incorporation into the permit, and until such documentation is
incorporated, the road segment cannot be approved for Phase I bond release.
The Oil Well Access Road is the upper(eastern) 1600' of Routt County Road 53C, which
provides access from Routt County Road 53 to an oil well that was in existence prior to
permitting of the Seneca II-W Mine. The remainder of the 1.62 mile Road 53C was permitted as
the Mine Entrance Haul Road(MEHR). The MEHR section of the road extends from RCR 53 to
a point beyond Sediment Pond 006, where the Oil Well Road section begins. Permit Attachment
20-2, Appendix 20-2.1 includes a letter from the Routt county Road and Bridge Department,
requesting retention of the entire length of RCR-53C, with a 28' travel width and gravel
surfacing. Observations made during the SL-2 inspection indicate that the Oil Well section
appears to have been constructed in general conformance with postmining design requirements.
Photo SL2-34 shows the upper end of the Oil Well Access Road. The MEHR section has not yet
been regraded to meet postmining standards, and retains operational haul road width and MSHA
required berms. The MEHR section was properly not included in the SL-2 release request,
however the Oil Well section was included in the SL-2 request. As-Built drawings have not yet
been provided for the Oil Well section, and Roy Karo of Seneca has indicated that it is SCC's
intention to provide the required As-Built documentation for the entire length of RCR 53C in a
single submittal, following completion of MEHR reclamation grading. As such, pursuant to
permit commitments and to ensure opportunity for review of the As-Builts and inspection of the
completed roadway by the Routt County Road and Bridge Department prior to Phase I bond
release, the Division's proposed decision for SL-2 will exclude the Oil Well section of RCR
53C.
Light Use Roads LU-1,LU3, and LU4 have been proposed as permanent roads in the approved
permit. Segments of each of these roads are located within the original permit area and were
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