REV14539

• Permit No: C1994082
• IBM Index Class Name: Revision
• Doc Date: 3/29/2004
• Doc Name: Adequacy Response
• From: Seneca Coal Company
• To: DMG
• Type & Sequence: TR25
• Media Type: D
• Archive: No

E~~i4
S Coaf Company'
iVlarch 26, 2004
Seneca Coal Company
REC~r)ifip
MAR ~ ~ 2004
Mr. vlike Boulay
Colorado Division of D4inerals and Geology ~iono(Miner~„ d
1313 Sherman Stxcet, Room 215 ep~'8Y
Dem~er, CO 80203-2273
(303) 866-4)36
Re: Yoast Mine (Permit No. C-94-082) -Technical Revision 25, Reclamation Plan Modifications,
Response to Technical 1\dequacy Review Comments
Dear Mr. Boulay:
F_ndosed are three (3} topics of revised and supplementa[ information for TR-Z5, cotresponding to
the following responses to the Technical Adequacy review comments, as outlined in your letter of
December 30, 2003.
Comment Ia: The Division cannotgrant a delay in contemporaneous reclamation for the reasons stated in Item > of
the November 7, 2003 7R-25 Cover letter (coincidental fartorr). The Division Gar not in the pastgranterl a delay in
contemporaneous reclamation due to the operator's ~oKS to meet coal production.
Further, the Division previously approved a variance request for this location due to increasingly d~calt mining
conditions (advancement ofmining equipment into steeper and narrower areas). Reference to advancement ofmining into
d~cult areas was added to Tab 19 page S of the perorit document with the subnrittad of Technical Revision 20
(submitted to the Division in December 2001), Mining egupment Gar already been advanced into this area. Topsoil
and overburden has been str~,6ed from the majority of the 2004 variance area.
The Division also recommerrdr removiirg from Tab 79 reference to d~cult operating constraints ~i.e.: advancement of
mining into steeper and narrower arear resulting in increased burden on existing equ pment fleet), and replacing this
language with a detailed written ana~~sis corder Rules 4.74.%(cf, 7.05.4(Z~(cf, and 2.05.3 (ZJ~a~, mare specifically
stating w/y additional time is necessary.
In reviewing this variance tzquest, the Divlslon rrotes that additional detail in the permit document will be reguired to
sufficiently correlate between the sequence ofmining and the timing of bnckflling and grading. The operations plan doer
not Contain a detailed timetable sufficient to describe the various mining phases proposed Gy the applicant. Likewise, the
reclamation plan should provide a detailed reprerentation of the timing of backflling and grading with respect to the
various miningpbases. Because of the numerous variance regarests and the lack ofsuffrcient detail in Goth the operations
plan and backpll andgrading plan, the Division is reguestirtg that the mine plan carne/ate with the backfill and grading
plan on ayear-by year basis. Please update the Operations P/aa (Exhibit >2-7J arsd the Backfzll and Gradin3 Plan
~Exbibit 79-7A) auordingly.
In accordance wftb Rule 2.05.3 f2~(a), ploase provide the following: A detail<d narrative description and appropriate
maps describing the land do be affected within the permit area according to the proposed sequence of mining and
rrc/amatiorz E''aCh narrative/nr~ shell include a detailed tirrrrtable sufficient to descrrbe the various mining phasc:r
proposed by the applicant Tfie maximum acreageproposed fa- each phase of the operations within the permit area must
be sped eed
Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639
Telephone [phone] • FAX [phone]