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May 16, 2011 C- 1982 - 057 /Seneca 11 -W Mine SLB <br />Area 6 is a crack that has opened up below the Oil Well Access Road in B Pit reclamation. Area 7 is a slide along <br />the Oil Well Access Road, in B Pit reclamation. Area 8 is a slide on the LU -2 cut face, above the road surface. <br />Area 9 consists of cracks below Haul Road A, upslope of the Pond 006 embankment. Area 10 is a small slide <br />below Haul Road A at the southeast inlet of Pond 006, Area 11 is a crack at the interface of the B Pit highwall and <br />regraded spoils. <br />Further up the 006 Gulch, near Stock Pond T -5, cracks were observed along the former highwall, extending into <br />the shrub enclosure on the north side of T -5 (Area 12 of Figure 2). The shrub plot slide (near the original aspen <br />study plot, along the reclaimed in -pit haul road) had failed again (Area 14 of Figure 2). At Area 13 of Figure 2, <br />small cracks were observed below the Ridgeline access road near the point where it crosses the 006 Gulch. <br />In the northern C/D Pit area several cracks were observed along the interface of the highwall and graded spoil near <br />Stock Pond T -20 (Areas 19 and 20 of Figure 3). <br />In addition to these new slide areas, additional movement was observed in the existing slide areas near Ponds 016 <br />and 016A, particularly upslope of the shrub plot area. <br />The Pond 017 drainage was not accessible due to muddy road conditions, so on the ground observations of the <br />slide near Stock Pond T -25 in the PM -1 drainage were not possible. <br />Several of the observed areas of instability (006 Gulch/Pits A and B, Pond 017 drainage, T- 20/Pits C and D) <br />are within areas that have undergone Phase I bond release. Since these areas will require extensive repairs <br />and additional ground disturbance, the operator will need to submit a technical revision to the approved <br />permit application that identifies the areas of disturbance (detailed map) and the proposed plan for repair <br />and long term stability of these areas. Additional performance bond will be required to implement the <br />approved revision. The Division believes these repairs are beyond normal maintenance and therefore, the <br />repairs on these areas will reinitiate the backfilling/grading and stability requirements for Phase I bond <br />release. These areas will be subject to the liability period of Rule 3.02.3 and the bond release criteria and <br />schedule of Rule 3.03.1. Once Seneca and the Division have an opportunity to evaluate the entire mine site, <br />we will determine what areas will be subject to the reinitiating of the liability period. <br />SIGNS AND MARKERS — Rule 4.02: <br />Mine identification and permit boundary markers were observed at the two entrances to the site on County <br />Road 53 and along the Tie - Across Haul Road (TAHR) corridor. Stream buffer zone markers were observed along <br />the MEHR and TAHR corridors. <br />Number of Partial Inspection this Fiscal Year: 9 <br />Number of Complete Inspections this Fiscal Year: 3 <br />Page 5 of 15 <br />