2013-09-20_REVISION - C1982057 ‎(3)‎

• Permit No: C1982057
• IBM Index Class Name: Revision
• Doc Date: 9/20/2013
• Doc Name: Adequacy Letter
• From: DRMS
• To: Roy Karo - Seneca Coal Company
• Type & Sequence: MR77
• Email Name: JLE
• Email Name: SB1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
September 20, 2013
Roy Karo
Seneca Coal Company, LLC.
P.O. Box 670
Hayden, Colorado 81639
RE: Seneca 11-W Mine; C- 1982 -057; Minor Revision No. 77 (MR77)
Adequacy Review No. 1
Dear Mr. Karo,
COLORADO
D I V I S 16 N OF
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta Pineda
Director
The Colorado Division of Reclamation, Mining and Safety (Division) received Minor Revision No. 77
(MR77) on September 11, 2013. The application was found complete for review on September 20,
2013. There are several issues that will need to be addressed prior to the approval of the revision.
Tab 22; Revegetation Plan
Revised page 24 updates the aspen nursery stock planting method to plant the root ball of the
aspen at ground level as opposed to the currently approved depth of five to six feet. However,
the revised sentence indicates that the aspen will be planted "very deep" and then indicates the
tree will be planted at ground level. Please revise this sentence to remove the commitment to
plant the aspen tree "very deep ".
2.) The second sentence of the last paragraph of the revised page 24 states, "Four square yards of
landscape fabric would be placed around the base of each tree or in a strip pattern ". A period is
missing at the end of the revised sentence; so it is unclear if the rest of the sentence and the
remainder of the currently approved paragraph were intended to be omitted or deleted from this
paragraph. Please correct this sentence and indicate if it was intended to delete the following
sentence which is currently included in the paragraph in question, "Cages of 2" x 4" 12 gauge
welded wire 72 inches tall would be placed around each and anchored with three t- posts."
Tab 25; Bonding
3.) The insertion instructions submitted the MR77 indicates to replace the existing information in
Attachment 25 -1 with the bond cost summary sheets. Rule 2.05.4 (2)(b) requires that each
permit include a detailed estimate of the cost of reclamation of the proposed operations to be
covered by the performance bond with supporting calculations for the estimate. Given this, in
addition to the summary sheets provided, Attachment 25 -1 should also include the CIRCES cost
estimate sheets which provides the supporting calculations for the estimate. The Division
provided Seneca Coal Company with the CIRCES calculation sheets with the Midterm Review
No.6 document. Please include these sheets in Attachment 25 -1 of Tab 25 of the permit. The
Division has a copy of the CIRCES cost estimate sheets so it is unnecessary to submit a copy of
these sheets in your adequacy review response letter.
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines