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SENECA PROPERTY, LLC - SENECA IIW MINE (C-82-057)
<br />PERMIT RENEWAL RN06 ADEQUACY RESPONSES
<br />1.) Rule 4.07: SP provided well abandonment reports to the division on May 29, 2015 for seven ground water
<br />wells. Please update Table 15.2 with the current status of all wells.
<br />Several wells in Table 15-2 report that monitoring has stopped. Have these wells been abandoned in
<br />accordance with rule 4.07.1(1) and applicable abandonment reports filed with the Division? Wells in
<br />question include: WW3, WW3, GW-S2W-30V,, WHAL7-2, WWTAL8, WWAL9, WW15, WWC17, and WTC
<br />200.
<br />Response: SP plans to abandon multiple groundwater wells in the near future (Spring 2017), with abandonment
<br />planned for the following wells: WW3, WWC3, WOV3, WWTAL8, WWTAL9, WW15, and WTC200. SP has
<br />revised Table 15-2, Ground Water Monitoring Site Summary, to reflect the 2015 well abandonment updates and
<br />included it in this submittal. The current Hydrologic Monitoring Plan, Appendix 15-3, was updated as part of the
<br />recent TR -82 Submittal.
<br />2.) Rule 4.05.9(13) and Stipulation No. 39: SP has previously been approved to allow ponds to remain as
<br />permanent features. Tab 20, Attachment 20-2, in the PAP shows that Ponds 005, 009, 015 have been
<br />approved by the Division as permanent ponds, and have been approved by the Colorado State Engineer's
<br />Office (SEO). Stock Ponds T-2, T-3, T-5, T-18, T-20, T-24, T-26, and T-27 have been approved as permanent
<br />features by the Division, and have received approval by the SEO.
<br />a. The Division has approved Ponds 006, 016, and 017 to remain as permanent features, but SP has not
<br />provided SEO's approval for these ponds. Please submit the appropriate State Engineer's office approvals
<br />for these three permanent ponds.
<br />Response: The SEO has issued a storage right for Pond 006, so it is effectively approved as a permanent
<br />structure. SP is providing copies of the SEO application and approval with this submittal. SP has contacted the
<br />local SEO office to arrange for inspection and approval of Ponds 016 and 017 as permanent impoundments,
<br />however, the SEO has not been available to complete this effort. SP will continue to pursue these approvals, and
<br />will provide that documentation when received.
<br />b. Stock Pond T-22 has not been approved as a permanent feature by the Division or SEO. SP conducted
<br />maintenance on this pond in 2014. SP will need to submit a Technical Revision in accordance with Rule
<br />4.05.9(13) for T-22, if it intends to retain this stock pond as a permanent feature.
<br />Response: SP anticipates that it will be beneficial to retain this stock pond as a permanent feature in conjunction
<br />with the approved postmining land use, and will prepare and submit a Technical Revision and obtain SEO
<br />approval in the near future.
<br />3.) For all permanent ponds and stock ponds, SP needs to provide the maintenance agreements in accordance
<br />with Rule 3.03.1(3)(c). Please note that this agreement is different from the agreements required by Rule
<br />2.05.5(1)(b) and Rule 4.03.2(g)(ii).
<br />Response: SP has established an agreement in accordance with the specific requirements of Rule 3.03.1(3)(c).
<br />This agreement can be found on page 5 of Tab 13. This agreement has been reviewed relative to the referenced
<br />regulatory requirements, expanded as appropriate, and is included in this submittal for replacement in the PAP.
<br />SP has agreed to take responsibility for the permanent impoundments through the Final Bond release time -frame.
<br />Once the Seneca I1W Mine has received final bond release, Seneca Property, LLC anticipates that the property
<br />will be sold, and the impoundment maintenance responsibilities (under the existing agreement) will be transferred
<br />to the new landowner(s) as part of the deed to assure future maintenance. For any interim period, SP will inspect
<br />and maintain the impoundments consistent with the existing maintenance agreement.
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