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SE/VEC.4 Seneca Coal Company <br />December 31, 2003 <br />Mr. Dan Mathews <br />Division of Minerals and Geology <br />101 South 3~, Ste 301 <br />Grand)unction,CO 81501 <br />(970)242-5025 <br />SCpNNtiD <br />RE: Seneca II-W Mine Permit C-82-057 <br />~~~~~v~® <br />JAN 0 d 2004 <br />division o} iNinerals and Geslt <br />Minor Revision 55 (MR-55), Abatement for CV-2003-014 <br />Dear Mr. Mathews, <br />Per the items stated in the CV-2003-014, issued on 11/21/2003, Seneca Coal Company is submitting the <br />following information as Step 1 Abatement outlined in the "Steps Necessary to Abate Violation" and a <br />formal request fora 90-day extension for the completion of Step 2 Abatement. <br />Step 1: Submit a detailed repair plan (minor revision) addressing stabilization measures to be <br />employed on gullies described under "Portion of the Operations". Include commitment to <br />eliminate old contour ditches that have caused or exacerbated gully erosion. Submit plan by <br />January 9, 2004. <br />• Step 2: Implement and complete approved plan required by Step 1 on or before February 19, <br />2004. <br />Step 1 Abatement compliance, preparation of a detailed rill and gully repair plan, is hereby submitted For <br />Division approval. However, due to climatic conditions (winter and spring), Step 2 Abatement of the rill <br />and gully repair plan cannot be implemented and completed until the summer of 2004 for various and <br />obvious reasons. <br />1. Snow cover during the winter months makes locating of the rills and gullies impossible. <br />2. Grading and topsoiling during winter and spring would require that spoil/topsoil be graded or <br />placed over saturated or near saturated (snow covered or extremely muddy) material. <br />3. Grading/placement of materials mixed with snow will cause additional erosion during spring <br />snowmelt. <br />4. Topsoil placement by scrapers under these winter conditions causes deep ruts and potential <br />unsafe operating conditions. The ruts would then have to be regraded again in the summer of <br />2004. <br />For these reasons, SCC res~ctfullxreauests tha[ the Step 2 Febmary ]9, 2004 completion date be <br />extended until June 1, 2004. SCC proposes to conduct the rill and gully repairs during the summer of <br />2004, as indicated in the attached Appendix 22-4, Rill and Gully Plan (2004). <br />Seneca Coal Company . P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-3707 . FAX (970) 276-3014 <br />