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Mr. Mike Baulay <br />Division ofMixerals and Geology <br />September 30, 2004 <br />Page 3 <br />9. The existing Backfzll and Grading Schedule Exhibit 13-2 contains a port mine channel schedule. Please update <br />and revise this schedule to include dates for final construction and completion of all post mine channels at the Seneca <br />77 Mine. <br />Response: The Post Mine Channel Schedule has been removed since all of the chazmels have been <br />constructed, however routine maintenance is ongoing as required. <br />10. Aevired maps submitted with this technical revision including Exhibits 12-1, 12-9, and 7-19 have incorrectpermit <br />boundaries shown in the aria of Pond 008. The disturbance boundary it shown extending beyond the permit <br />boundary in the vicinity of Pond 008 and to the north of Pond OOB. Please revue there exhibits to show the mrrect <br />permit boundary. <br />Response: The exhibits have been updated to correctly depict the permit boundary location. <br />> >. The new location for the Petroleum Contaminated Material Stockpile appears to be located at the head ofa port <br />mine channel and major drainage. SCC should consider moving the stockpile out of the immediate vicinity of the <br />drainage to ensue that leachate or runoff from the pile doer not enter into any water way. Then also doer not <br />appear to [beJ any discussion of the Petmleum Contaminated Material Stockpile in the permit text. Please update <br />the non-coal waste section of the PAP to include information about this stockpile, the ultimate disposition of the <br />stockpile, and any measures taken to prevent leachate or runoff from entering into surface water orgroundwater. <br />Response: The new location of the Petroleum Contaminated Material Stockpile is located at the <br />headwaters (not within) of a proposed post mine channel This channel will not be established <br />until after the Petroleum Contaminated Material Stockpile (along with the adjacent Solid Waste <br />Disposal Site) have been backfilled and graded (sometime after the facilities azea has been <br />reclaimed). During operation, a berm will be placed around the stockpile area to contain and/or <br />direct surface water runoff. Any potential runoff escaping from the stockpile azea will ultimately <br />be contained in the Solid Waste Disposal azea. However, based on your concern, the stockpile has <br />been moved slightly to the SW to further remove it Erom the area in question. Exhibit 12-1, <br />Operations Plan, shows the adjusted location. <br />Landfills aze regulated by the Colorado Department of Public Health and Environment's <br />Hazazdous Materials and Waste Management Division (HMWMD). In the HMWMD's <br />"Regulations Pertaining to Solid Waste Sites and Facilities, Part 1" (6CCR 1007-2) an exemption to <br />obtaining a "certificate of designation" is granted to mines permitted by the CMLRB (see section <br />1.4.2). SCC will use the HMWMD's guidance document "Information Regazding the Management <br />of Petroleum Contaminated So$" (available on their website) in managing the stockpile. <br />SCC has revised the "Coal Processing and Non-Coal Processing Wastes" section of Tab 12, to <br />provide information on management of the stockpile. <br />SCC has reviewed and discussed the requirements for the mid-portion of channel SIIPM-8 and elected <br />to redesign the channel into more portions than just "upper" and "lower". There is a relatively flat <br />section just above the junction of SIIPM-13 that is not conducive to channel construction since it is <br />very swampy and will not support equipment. This 600-foot section will be left as a broad vegetated <br />channel. Directly below, where the channel slope steepens an azmored channel has been constructed <br />per original design. The SEDCAD runs and channel designs aze included with this submittal. <br />