REV95567

• Permit No: C1980005
• IBM Index Class Name: Revision
• Doc Date: 1/16/2007
• Doc Name: 3rd Response to Adequacy Comments
• From: DRMS
• To: Seneca Coal Company
• Type & Sequence: TR40
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman 6t., Room 215
Denver, Colorado 80203 C O L O R A D O
DIVISION O F
Phone: [phone] RECLAMATION
FAX: [phone] M I N I N G
January 16, 2007 I SAFETY
Roy Kazo Bill Owens
Seneca Coal Comgany Governor
P.O. BOX 670 Russell George
Executive Director
Hayden, CO 81639
Ronald W. Canany
Division Director
Re: Seneca II Mine TR-40 Natural Resource Trustee
File C-1980-005
3rd Response to Adequacy Comments
The Division of Reclamation, Mining, and Safety (Division) has completed our review of
the referenced response submittal, dated December 27, 2006, and we have discussed the
submittal with Liza Rossi of the Division of Wildlife (DOW). DOW indicated that they
will provide a final review letter shortly, and the Division will forwazd this to SCC as
soon as it is received. Our specific review comments aze provided below.
Division has concluded that the currently approved interim monitoring plan is
adequate, and we will not require modification of the plan at this time. However,
if review of monitoring data or field checks conducted over the 2007-2012 permit
term within BRB-4 indicate a low potential for achievement of shrub standazd
success within a reasonable timeframe, monitoring plan modifications (to
incorporate shrub patch mapping/sampling) andJor remedial shrub establishment
measures may be required.
Item Resolved.
2. Given the seedmix modification proposed, and other factors recently discussed
with SCC representatives, the proposed plan is acceptable. Should a revision
application for facilities retention not be submitted within 2007, the Division may
request that the reclamation plan for the BRB-5 northern pazcel be amended to
include appropriate woody plant establishment enhancement measures.
Item Resolved.
The "81-1"reclamation parcel has been included within BRB-1, the "pre-law"
bond release block. Apparently, the block was mined sometime prior to August 3,
1977, but was initially seeded in 1981. The question of whether the azea had been
initially disturbed prior to February 25, 1976 was not resolved, but the Division
has determined that for the purposes of the bond release process at Seneca II
Mine, the determination would not make any practical difference.
We have concluded that it is appropriate to include the various azeas mined prior
to August 3, 1977 within BRB-l, as indicated on Exhibit 13-13.1. This approach
Office of Office of
Mined Land Reclamation Active and Inactive Mines