APPCOR13368

• Permit No: C1982057
• IBM Index Class Name: Application Correspondence
• Doc Date: 2/19/1985
• Doc Name: SENECA II WEST APPLICATION RESPONSE ADEQUACY REVIEW
• From: MLRD
• To: ANNE BALDRIGE
• Media Type: D
• Archive: No

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DEPARTMENT OF NATURAL RESOURCES
David H. Getchea. Eaecutne Director
MINED LAND RECLAMATION DIVISION
DAVID C. SHELTOH, Director
Richard D. Lamm
Governor
DATE: February 19, 1985
T0: Anne Baldrige
FROM: Jim Pendleton _` ~``~~-
RE: Seneca II Weyt"Appli ion Response - Adequacy Review
Pursuant to your request, I have completed a review of my assigned technical
topics. While the applicant has significantly improved the technical adequacy
of the amended application, I have discerned a few remaining deficiencies,
Rule 2.04.3(6) - Overburden
The blasting plan portions of this section have been amended and now
satisfy the regulatory requirements of rules 2.05.3(6)(a) and 4.08, No
excess spoil will be generated during the operation. Therefore, no
response is required to this section of our regulations.
Rule 2.05.3(8) - Coal Processing Waste and Non-coal Processing Waste
No coal processing waste will be generated at the mine site. The
applicant does intend to dispose of non-coal processing waste (grease,
lubricants, paints, flammable liquids, garbage, abandoned mining
machinery, lumber, and other combustibles) within a designated site
adjacent to the surface facilities area. The application states that
disposal will occur in accordance with applicable state regulations.
This response is inadequate. Based on the applicant's brief
description of the intended wastes, it will be necessary to provide
sufficient design detail to demonstrate that the waste structure will
not be a pollution source. The applicant has several options:
(1) The applicant could carefully define the waste to be disposed of,
in order to demonstrate their non-pollutant character, or
(2) The applicant could submit an adequate design, in accordance with
2.05.3(8)(a), which would assure retention of all possible
pollutants, filtrates, and leachates, Alternatively,
(3) The applicant could dispose of the non-coal wastes in an approved
off-site disposal facility.
423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. [phone]