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October 37, 2005 Mr. Mike Boulrry Divi.don ofMinerak and Geohgy Page 2 Response: The permanent roads at the Seneca II Mine retained as part of the post-mine landscape generally will be narrowed to 20 feet wide as described on pages 13-45 and 13-53. Exceptions are Road E and the lower portion ofRoad EI (from station O+0 to approximately station 20+18). Roads E and El will be narrowed to 22 to 24 feet in width to facilitate oil tanker truck and other private vehicle access to existing oil wells located south and east of the permit boundary. The road List heading, found in the legend on Exhibit 13-2A, Port-Mine Topography and Permanent Features, has been revised to "Roads to be Narrowed" as suggested by Colorado Division of Minerals and Geology (CDMG) staff. Permanent road cross-sections are shown on Exhibit 13-2B, Permanent Road Cmrr-Sections, while the longitudinal profiles aze shown on Exhibit 13-2C, Permanent Road Profiles, Please note that Exhibit 13-2A also shows the "Pre-Law Road", which is a permanent road that will not be narrowed as this road is apse-existing road not subject to the rules and regulations of the Colorado Mined Land Reclamation Board for Coal Mining. Exhibit 13-2, Backfill and Grading Schedule, has also been revised as requested by CDMG staff. The PAP has been revised to incorporate the permanent road information requested by CDMG. The revised information is included with this response package and should be inserted into the PAP in accordance with the accompanying insertion instmctions. 2 - 7. Responses accepted Response: No responses needed. 8. Pkare pmvideAr-Built Certifzcataon(rJ for allpart-mine drainage channels that drain a watershed of ai least one rquarz mik above . the diversion, intermittent, orperennial streams within the permit area. The ar-buik certiftcation(sf should be submitted under this technical revision ar site conditions allow access to all areas of the mine at this time. Response: Drainage azea calculations performed by SCC indicate there is only one drainage channel that collects runoff from a watershed that is greater than one squaze mile. This drainage channel is identified as SIIPM-1. This response package contains an as-built certification fox Channel SIIPM-1 which demonstrates compliance with Rule 4.05.4(2). The certification report (Appendix 7-12.1, As-Built Report Drainage Channel SIIPM-1) should be inserted into the PAP in accordance with the accompanying insertion instructions. Additional Comments In response to comment 12 of the TA-36 adequacy letter dated Decrmber 28, 2004, SCC stated that they would provide updated water quality documentation and water rights information for Ponds 002, 003, and PECOCO Impoundment and permanent impoundment documentation for Ponds 004 and 008 as part of the TR for the Mid-te»n Review. During a complete inspection on March 15, 2005 the CDMG noted as-built cer[iftcation reports were mirsingforPandr 002, 003, 004 and the Truck IY/ash Ponds. The CDMG requested that this information be incorporated into the PAP via a technical revision. SCC her provided updated water quality and water tights information with this technical revision (I'Li'-37f for all impoundments and provided As-Built Cert~cation Repmxr for Ponds 002, 003, and the Truck Wash Ponds. As part of thin Mid-Term Review and asraciated technical revision (IR-37J, the CDMG has reviewed all perntanent impoundment demonrtmtionr and As-Built Certifzcationr for all impoundments. The CDMG her the following additional comments regarding proposed permanent impoundments. 9. The water quality demonnratians are acceptable ar submitted for all propa.red permanent irttpoundmentr. The CDMG and the Office of the State Engineer are nrrrently reviewing the water rights information. The Office of the State Engineer indicated to Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 Telephone (970) 2763707 • FAX (870) 276-3014