REV97683

• Permit No: C1980005
• IBM Index Class Name: Revision
• Doc Date: 8/10/2007
• Doc Name: Adequacy Review
• From: DRMS
• To: Seneca Coal Company
• Type & Sequence: TR43
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203 C O L O R A D O
Phone: [phone] DIVISION O F
RECLAMATION
FAX: [phone] M I N
I N G
cc
- tY-
SAFETY
August 10, 2007 gill Rit[er, Jr.
Governor
Mr. Roy Karo Harris D. Sherman
Seneca Coal Company Executive Director
P.O. Box 870 Ronald W. Cattany
Ha den
Colorado 81639
y Division Director
, Natural Resource Trustee
Re: Seneca II Mine (Permit No. C-1980-005)
Technical Revision No. 43 (TR-43)
Permanent Retention of Facilities -Adequacy Review
Dear Mr. Karo:
We have reviewed Seneca Coal Company's (BCC's) response to our April 20, 2007 adequacy
review letter regarding TR-43. We had asked SCC to address two remaining issues regarding
permanent retention of certain facilities on site. BCC's response did not adequately address the
issues, so they are reiterated more specifically as follows.
We requested, consistent with Rule 2.05.5(1)(a), that SCC explain how the remaining facilities
would be compatible with the approved post mining land use (rangeland). SCC responded with
a referral to an attached letter from Grassy Creek Holding Company, the landowner. In the
letter, Grassy Creek Holding Company summarizes possible uses for some of the facilities, but
adds that additional time is necessary to properly assess what existing facilities may be used
both short and long term.
The Division also requested, consistent with Rule 2.05.5(1)(b), that SCC provide comments
from the county regarding permanent retention of the facilities. SCC noted that it could be
assumed that Routt County would provide comments to us upon request. We solicited
comments from Routt County on March 15, 2007. To date, the only comments we have from
the county are those dated April 11, 2007 which were forwarded to SCC on April 20, 2007.
Those comments indicate that the county would not be in favor of facilities retention without
additional information from SCC regarding their proposed use. The county also noted that
separate use permits might be required for retention of certain facilities, and we are not aware
that SCC or Grassy Creek Holding Company has applied for or obtained any separate use
permits.
Since the requirements of Rules 2.05.5(1)(a) and (b) have not been met, we are unable to
approve the revision at this time. Therefore, we request that SCC either withdraw TR-43
(leaving BCC's approved plan to reclaim all of the facilities areas intact); or provide all of the
following documentation in order for the Division to approve the existing TR-43 application:
Office of Office of
Mined Land Reclamation Denver Grand Junction Durango Active and Inactive Mines