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pFCEIVFD III IIIIIIIIIIIIIIII 999 OCT 1 g 1997 ENECA Coal Company :,,,~,,,, Seneca Coal Company October 13, 1997 Ms. Erica Crosby Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver, CO 80203-2273 RE: Seneca II-W Mine, Permit C-82-057, NOV No. C-97-015 Dear Ms. Crosby: In response to NOV No. C-97-015 f Coal Company respectfully submits believe this will provide the additional data that may prove to ~r the Seneca II-W Mine, Seneca the following information. We Assessment Officer with some be beneficial. The NOV was written for failure to maintain the primary spillway and maintaining the nonclogging dewatering device, as well as passing outflow through the emergency spillway at pond 006. To abate the violation, Seneca was required to unplug the primary spillway by 5:00 P.M. on September 26, 1997, the day the NOV was issued. Following is the precipitation data that the Seneca II-W Belfort rain gauge recorded for the storm events prior to issuance of the violation: Thursday, Sep. 18th 1.25 inches Friday, Sep. 19th 1.80 inches Saturday, Sep. 20th 0.82 inches Sunday, Sep. 21st 0.33 inches Monday, Sep. 22"d 0.16 inches Wednesday, Sep. 24th 0.01 inches Friday, Sep. 26th 0.35 inches The total amount of precipitation for this period amounts to 4.72 inches. The 10-year, 24-hour storm event for Seneca is 1.70 inches, which was exceeded on Friday the 19th. In addition to this, from 6 a.m. on the 18th to 6 a.m. on the 21st, the mine received 4.05 inches. Regulations 4.05.6(3)(a) and 4.05.6(4) were cited as portions of the violation. Based on the data presented above, the mine received greater than a 10-year, 24-hour event and that the pond was functioning as designed and that the emergency spillway was capable of passing the runoff above and beyond the required amount. Seneca Coal Company • P.O. Drawer D • Hayden, Colorado 61639 Telephone (970) 276-3707 • FAX (970) 276-3014