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A,"k RE's�� D <br />SENECA <br />Property, LLC 0c1 ` `�'��� Seneca Property, LLC <br />Janet Binns )MSION 0 ff KA October 11, 2016 <br />Division of Reclamation, Mining, and SaMONO AND SAFETY <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />RE: Seneca Property, LLC —Seneca II West Mine (Permit C-82-057), Minor Revision (MR16-83) — <br />Sediment Pond Capacity Survey Frequency Reductions <br />Dear Mrs. Binns, <br />Seneca Property, LLC (SPL) requests CDRMS approval of a Minor Revision (MR16-47) to our approved <br />Permit for the Seneca IIW Mine, for a reduction in the frequency of sediment pond capacity surveys. SPL <br />requests a variance from the requirement to conduct annual surveys of sediment ponds, as required by Rule <br />4.05.9(15)(C). The sediment ponds throughout the Seneca IIW Property have been surveyed on an annual <br />frequency throughout the reclamation period. From 2008 to 2015, SPL has seen minimal storage capacity loss <br />in all of the sediment ponds. Table 13-3 from the Annual Reclamation Report has been attached for a visual <br />reference of the history of the storage capacity levels. The Seneca IIW Mine Property is currently in the <br />reclamation phase and has established a great stand of vegetation which has substantially reduce the sediment <br />flowing in to the sediment ponds, therefore SPL does not see annual capacity surveys on the sediment ponds <br />to be necessary. In addition, SPL has ruled the procedure for which SPL conducts pond capacity surveys to <br />be unsafe. <br />With this revision submittal, SPL is requesting that Ponds 005 and 009 be reduced to visual sediment <br />inspections on an annual frequency. These two ponds generally do not flow year round which would allow <br />SPL to inspect the inlet for deltas, which would indicate sediment build up. For Sediment Ponds 006, 015, <br />016, and 017, which generally flow year round, SPL is requesting a reduction from annual capacity surveys to <br />a frequency of conducting capacity surveys every five years and visual inspections annually. <br />The application package contains the following: <br />• Minor Revision Application <br />• ARR Table 13-3, for visual reference <br />• Insertion Instructions <br />• Revised Permit Text <br />We look forward to working with you to facilitate timely review and approval. Please review, and feel free to <br />contact me with any questions on this application or related matters. <br />Sincerely, <br />Miranda Blomquist <br />Engineering Technician- Environmental <br />Peabody Energy- Seneca Property, LLC <br />Seneca Property, LLC • 29515 Routt County Road #27 • Oak Creek, Colorado 80467 <br />Telephone (970) 870-2718 <br />