REV05813

• Permit No: C1980005
• IBM Index Class Name: Revision
• Doc Date: 12/4/2006
• Doc Name: Response Review Memo
• From: Dan Mathews
• To: Mike Boulay
• Type & Sequence: TR40
• 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]
COLORADO
DIVISION OF
RECLAMATION
MINING
Sc-
SAFETY
DATE: December 4, 2006 gill Owens
Governor -
TD: Mlke BOlllay Russell George
Executive Director
FROM: Dan MatheWS Ronald w. Canany
Division Director
Natural Resource Trustee
RE: Seneca II Mine TR-40
File C-1980-005
Last week I discussed SCC's 8/16/06 submittal that was made in response to DOW's June 22, 2006
letter with Liza Rossi of DOW. In addition, I have reviewed my TR-40 file notes, and it appears
that there are a couple issues discussed during the meeting of June 8, 2006 involving DRMS and
SCC representatives, that have not been resolved. I recommend that we forward the following
requests to SCC. Items 1 and 2 reflect concerns based on my discussion with Liza Rossi; Items 3
and 4 are based on discussions from the June 8, 2006 meeting.
DRMS advises that SCC not wait until final bond release application is imminent to map
and sample shrub concentration areas within Block 4- Mapping of developing shrub areas
should be feasible by year 5 (2008 for the most recently seeded areas). Delineation of the
developing shrub stands and interim shrub density sampling within the block would allow
for assessment of the apparent potential for compliance with the approved standard and
identification of the need for remedial measures (if any) within a reasonable time period.
We would recommend that the interim monitoring plan be revised to substitute shrub
concentration area mapping and shrub density sampling within Block 4, for the current
parcel specific monitoring, on a periodic basis beginning in 2008. Please revise the interim
revegetation monitoring plau to include periodic shrub concentration area mapping
and shrub density sampling for Block 4, beginning in 2008.
2. Bond Release Block 5 (not yet reclaimed) will be subject to the same shrub standard as
Block 3 and Block 4, but the reclamation plan has not been revised to incorporate shrub
establishment enhancement measures. Please review the current reclamation plan and
include appropriate shrub enhancement measures to be applied within the Block 5
area. At a minimum, the plan should be amended to include mountain big sagebrush
in the primary upland seedmix (sagebrush seed to be broadcast or dribble seeded), and
narrative should be amended to include one or more concentrated shrub
seeding/planting areas within Block 5. Soil depth variation and protective fencing of
shrub planting areas should also be given consideration.
3. At the meeting of June 8, 2006 in the DBMS Denver office, it was discussed that, in order
for Parcel 81-1 to be retained within Block 1, SCC would need to provide documentation
Office of Office of
Mined Land Reclamation Active and Inactive Mines