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<br /> <br /> <br /> STATE OF COLOlZADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparlmenl of Natural Resources <br />l J l 3 Sherman 51.. Ronm ? 15 J+tl <br /> <br />Denver, Color, do AW03 ~~ <br /> <br />Phone: (3031 866-3567 III <br />FA% (303183'-8106 <br /> DEPARTMENT OF <br />DATE: May 25, 1995 NATU~- <br /> RESOURCES <br /> <br />TO: Erica Crosby ~ o per <br />co e <br /> n f <br />lames 5. Lochhead <br />FROM: Janet Binns ~ E.eculive Dneclnr <br />Michael B. LnnF <br />RE: Yoast Perm quacy Responses Dnosion Dueuor <br />I have finally had an opportunity to review and research Seneca Coal Company's <br />responses to the Division's adequacy concerns of January 20, 1995. Responses <br />numbered; 72, 73, 77, 78, 79, 80, 81, 82 pertain to items of concern I had identified in <br />the original adequacy review. <br />Seneca Coal Company's responses address my concerns as follows: <br />72. Seneca's response is suitable. During the first permit term Seneca Coal <br />Company has stated that they will replace topsoil upon 242.6 acres to an <br />average thickness of 1.8 feet. Seneca has also committed to replacing an <br />average thickness of 1.1 feet of topsoil along hau[ roads A and B and the <br />facilities area. <br />Life-of-mine topsoil replacement depths will average 1.6 feet in thickness. <br />Since 1.6 feet represents an average over the entire mine area, while the <br />first permit term reclaimed area will receive a 1.8 average topsoil <br />replacement thickness, Seneca will need to provide more detail on <br />proposed topsoil replacement thicknesses prior to the second permit term. <br />Seneca added a minimum topsoil replacement thickness commitment on <br />Tab 21 page 23. This commitment states that a minimum thickness of 1.0 <br />feet in the mine area and a minimum thickness of 0.5 feet will be replaced <br />along the Haul Roads A and B. While the Division recognizes that a <br />degree of variability is inherent in reclamation activities, this variability is <br />in the magnitude of 50 percent of the average depths. This variability <br />seems excessive. The Division feels that a commitment should not deviate <br />to such extreme from the proposed average. <br />73. Not all landowner consent forms have been received. At this time Haul <br />Roads A and B cannot be approved to remain as permanent. <br />