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III IIIIIIIIIIIIIIII 999 STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY D•~l ianmrm w Ndlurdl Hramrces I I I V Sherman 51.. Ruum _' I i Denv~r, G,luradu II1110) Phunr:I 111;1 ^hh- 15Gi DATE: February 36. 1999 TO: Mike Boulay and Sandy Brown FROM: Joe Dudash -trr, r~ ,~ RE: Identification of Interests Adequacy Review ` Permit Revision No. 2, Seneca II W, C-32-0~7 / IVlinor Revision No. 13, Yoast Mine, C-94-032 iVlinor Revision No. -t9, Seneca II iVline, C-30-005 DIVISION O F h11NERAlS GEOLOGY 0. E C l A M A T I O N r~11NING•$AFE7Y gill Owens Governor Ore; E. Wapner Execuove Dirrclor .wchael B. Lang Div~sinn Ovenar I have finished my review of Seneca's responses to the Identification of Interests questions in our November 2=4, 1993 adequacy review letter for the Seneca II-bV Mine. The information is relevant for all 3 Seneca mines. The format of this letter conforms to the adequacy letter format. The file is located at m:\coal\mpb\senamem2 and m:\coal\sb 1 \senamem'. A check of the AVS has tzrrned ttp a "conditional issue "for Seneca Coal Company. The company has been linked to seven violations, s:.r of the violations are from Kentucky and one is from YVest Virginia. Seneca does not have to otivn or operate the mine that has received a violation in order for Seneca to be linked to the violation. According to Colorado regulations, the link to a violation ccrn occur because an individual in one company was related to another compare}• which had received the violatiaz. The Kentzcky violations involve a company called Catativba and have been covered previously in permit stipulations for the three Seneca mines. However, the bYest l'irginin violation, which involves the con:parzv called :L1arNr:.4c.. rs new crud needs to be added to the stipulations. The Diviston will revise the npproprizue stiptdations jor the t!vee Seneca mines and contact Seneca about these revisions. The Division will revise the appropriate stipulations for all three mines at the time of revision approvals. Seneca has avreed ro this.