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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />General Comments <br />This was a partial mine site inspection, conducted by Dan Mathews of the Division's Grand Junction office, <br />accompanied by Dennis Bugay of Seneca Coal Company (SCC). Weather was cloudy and cool. Inspection was <br />limited to those areas accessible from the north end of the permit area along Road E1 up to the junction with the <br />South Road. Beyond the South Road junction, vehicle access was prevented by muddy conditions. There was <br />fresh snow cover from snow the previous night, patchy in the shop vicinity; 2-3 inches at higher elevations along <br />Road E-1. Most of the winter snowpack had melted off the reclaimed areas accessible from Road E-1 in the last <br />week or two. <br />Signs and Markers <br />The Mine I.D. sign had not yet been updated with the correct SCC physical address and phone # as requested in <br />the previous inspection. Operator indicated that stickers with the corrected information were on order and would <br />be applied to Mine I.D. signs as soon as possible upon receipt. <br />Roads <br />Road E-1 was the only road travelled. It was in good condition up to the vicinity of the South Road junction, but <br />muddy a short distance beyond the junction in areas subject to heavy drifting. It is likely that as roads dry and <br />the entire permit area becomes accessible, typical spring road maintenance activities will be warranted in <br />various locations. <br />Hydrologic Balance <br />Sediment Ponds 002 and 003 were checked. Both ponds were full and discharging clear flow, with no problems <br />evident. The shop area perimeter collection ditch to Pond 003 was properly maintained and functional, as were <br />SAE straw wattle sediment controls for the small disturbed area north of the E/E-1 Road junction in the facility <br />area. <br />Backfill and Grading <br />Upper portions of the PM-10 reclaimed watershed were walked during the inspection. Specific locations <br />observed included the 8 acre reclaimed solid waste disposal area, which was included in the SL-4 Phase I bond <br />release application (not yet approved), and adjacent locations including the site of former Topsoil Stockpile "P", <br />which were included in the previously approved SL-1 Phase I bond release. Maintenance grading and channel <br />repair is warranted at several locations in the general vicinity. <br />A portion of Stockpile "P" was located on a relatively steep slope west of the PM-10 channel. The <br />reclaimed stockpile slope segment is a corridor approximately 150 feet wide. There are remnant topsoil <br />berms along the edges of the corridor, which need to be graded out to better blend the recent topsoil <br />corridor reclamation with the older established reclamation on either side. Also, rills have formed along <br />the lower half of the corridor. Vegetation is becoming established, but further measures are warranted <br />to curtail erosion in the interim. Please grade out the remnant topsoil berms to blend the corridor <br />into the adjacent terrain, and install a series of closely spaced contour furrows or water bars to <br />control erosion along the lower half of the reclaimed corridor. Seeding of the re-disturbed areas <br />will be necessary. <br />Maintenance is warranted along the section of turf-reinforcement mat (TRM) lined channel at the lower <br />end of the reclaimed solid waste disposal site, where the TRM has become dislodged and folded over <br />along the lower end of the installation. Please repair as necessary. <br />3