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Attachment 20-2 text includes commitments to provide As-Built profile and cross-sections for each <br />of the permanent light use roads, RCR 53C, and Road "J", prior to Phase I bond release request. The <br />"J" Road As-Built cross-sections in the approved permit reflect the operational road width, but do not <br />reflect the reclamation modifications including the reduced width. <br />The primary Landowner Access Road is comprised of several segments of designated roads (Road <br />"G", Ridgeline Access Road, Road "J", Connector Road, and Road "K") that were modified to <br />provide permanent access through the reclaimed area. Figure 1 shows each road segment. Road G <br />provides access from Routt County Road 53 (Dry Creek Road) into the north end of the original <br />permit area for a distance of slightly over 1 mile, at which point it assumes the designation of <br />Ridgeline Access Road. The Ridgeline Access :Road, the longest road segment, runs most of the <br />length of the reclaimed original permit area from north to south, to its intersection with Road "J", <br />which provides access from the Ridgeline Access Road into the South Extension Area. Road G and <br />the Ridgeline Access Road are contained entirely within the original permit area. A short initial <br />segment of Road "J" is in the original permit area, while the remainder of Road "J", the Connector <br />Road, and Road "K" are in the South Extension Area. The road segments that comprise the <br />Landowner Access Road within the original permit area comply with the permanent access road <br />criteria as specified in the PAP, including drainage systems, gravel surfacing, MSHA berms removed, <br />and 20 foot travel width, with roadsides and cut and fill slopes revegetated. Observations made <br />during the SL-2 inspection are in the road section of the bond release inspection report. <br />The Oil Well Access Road is the upper (eastern) 1600' of Routt County Road 53C, providing access <br />to an oil well that was in existence prior to permitting of the Seneca II-W Mine. The remainder of the <br />1.62 mile Road 53C was permitted as the Mine Entrance Haul Road (MEHR). The MEHR section of <br />the road extends from RCR 53 to a point beyond Sediment Pond 006, where the Oil Well Road <br />section begins. Permit Attachment 20-2, Appendix 20-2.1 includes a letter from the Routt county <br />Road and Bridge Department, requesting retention of the entire length of RCR-53C, with a 28' travel <br />width and gravel surfacing. Observations made during the SL-2 inspection indicate that the Oil Well <br />section has been constructed in general conformance with postmining design requirements. However, <br />final grading of the MEHR has not been completed and as-built certifications for the Oil Well Access <br />road have not been submitted. Roy Karo of Seneca stated that it is Seneca's intention to provide the <br />required As-Built documentation for the entire length of RCR 53C in a single submittal, following <br />completion of MEHR reclamation grading. As such, the Division's proposed decision for SL-2 will <br />exclude the Oil Well section of RCR 53C. <br />Light Use Roads LU-1, LU3, and LU4 have been proposed as permanent roads in the approved <br />permit. Segments of each of these roads are located within the original permit area and were <br />requested for Phase 1 release within SL-2. See Figure 2 for the locations of these road segments. <br />LU-1 provides access from the permanent Ridgeline Access Road up to a high point on the ridge <br />where the electrical substation is located. LU-3 and LU-4 are collectively referred to as the <br />"Ridgeline Light Use Road" (LU-4 is in essence a continuation of LU-3). LU-3 diverges from the <br />Ridgeline Access Road in the upper 006 Gulch watershed and extends south along the eastern <br />ridgeline to provide landowner access to properties in the South Extension of the permit area. The <br />length of each of the road segments within the original permit area subject to SL-2 release request <br />was travelled during the inspection, and no problems were noted. As-Built documentation for the <br />15