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iii iiiiiiiiniii iii <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />t313 Sherman St.. Room 215 <br />Denver. CO 80203 <br />303 8663567 <br />FAx~ 303 632~8t06 <br />STATE~F COLORADO <br />OF CpC~ <br />l~~ R9 <br />--~x,n~ <br />~~'Q ~$ <br />• , 6~. <br />Roy Romer, <br />Governor <br />September 09, 1992 <br />Mr. Gary W. Wendt <br />Peabody Coal Company <br />1300 South Yale <br />Flagstaff, Arizona 86001 <br />RE: Seneca II Mine (C-SO-005) <br />Permit Renewal 02 <br />Dear Mr. Wendt: <br />Michael8 Long. <br />Division Direnor <br />The Division has completed its review of your application for the second permit renewal at the <br />Seneca II Mine. As we discussed earlier today, a few additional adequacy concerns were <br />identified. Those concerns are as follows: <br />1. Page 13-64 indicates that cover measurements for determination of revegetation <br />success will be based on basal cover. Total vegetative cover data has been <br />collected over the past years for both reclaimed areas and reference areas. If <br />basal cover is to be used for success determinations, the vegetation monitoring <br />plan should be modified accordingly. Alternatively, page 13-64 could be revised <br />to indicate that total vegetative cover will be used for cover comparisons between <br />reclaimed areas and reference areas. <br />2. Rule 4.09.1(11) requires that all excess spoil fills be monitored quarterly for <br />instability, structural weakness, and other hazardous conditions, with a certified <br />report of the inspection forwarded to the Division within two weeks of each <br />inspection. Since completion of the underdrain system at the Wolf Creek Fill, the <br />Division has not received inspection reports for the fill. Peabody should <br />commence quarterly inspection of the fill, as required by Rule 4.06.1(11), <br />beginning with the fourth quarter of 1992. A commitment to monitoring of the <br />fill should be included in the permit application package within thirty days. <br />3. Predictions of Probable Hydrologic Consequences, in Tab 7 of the permit <br />application, were compiled in 1981, and updated with the 1986 permit renewal. <br />The section should be updated to include findings based on monitoring at the site <br />since those predictions were made. Specifically, section A.2.c., "Parameters in <br />Effluent That Have Exceeded Water Quality Criterion", section B.l.b., pit inflows, <br />