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E~~i4 <br />CoalCompsny <br />August 8, 2003 <br />Mr. Daniel T. Mathews <br />Division of Minerals and Geology <br />101 South 3~, Ste 301 <br />Grand Junction, CO 81501 <br />(970) 242-5025 <br />RE: Seneca II-W Mine, Pemtit C-82-057, MR-54 <br />Response to Adequacy Concerns <br />Mr. Mathews: <br />Seneca Coal Compan <br />REC~o~~D <br />AUG 1 i ZoJ3 <br />D1VlSi0n of Minerals and Geolo®y <br />Enclosed please find two (2) copies of responses to your letter of]uly 21, 2003 for MR-54 to the <br />Seneca IT-W Mine Pemvt C-82-057. A required third copy has been sent to you and addressed to the <br />.Division Offices at 1313 Sherman Street, Denver, CO. <br />Cost Estimate -SCC accepts the estimated liability amount of $63,937 for reclamation of the <br />proposed project. The new approved bond amount for the II-W Mine will be $8,950,763 and there <br />is $9,000,000 currently held by the Division. <br />1. Narrative indicates that each drill pad will contain an earthen berm on the downrlope perimeter to control surface <br />runoff. Sizing rpeciftcationr and demonrtrationr are notprovided Alro, it it not dear fmm the narrative whether <br />the berm would be retained to pmvide sediment control fallowing reclamation, or whether other measurer such as <br />surface roughening would be utilized to provide sediment tonim! fallowing reclamation. <br />Several of the proposed locations would appear to fall outride aJ the drainage basins of approved sedimentation <br />pandt (eg. #2, #3, #4, #8, #10, #12, #14, #16). As rush, small area exemption provisions af4.05.2(3) <br />would appear to be applicable. Please provide sediment control details and documentation to demonstrate that <br />drainage from the drill .cites will meet the went limitations of 4.05.2, both during drilling and following <br />reclamation. <br />One or mare "typical" sediment control demonrtratiora for active and reclaimed drill pads may be appropriate, <br />bated on rite speciftc slope and soil conditions, as an alternative to separate demonstrations for each site. In order <br />to avoid the `impoundment" ffect of a sediment tvnhvl berm, it is requested that silt fencing or berm breaks with <br />ftlter fabric installations, or a similar, filtering approach be utilized for reclaimed rites where surface roughening <br />alone will not be sufficient to demonstrate compliance. <br />Response; As suggested by the Division, SCC requests Sma- Area Exemptions fot drill sites #2, #3, <br />#4, #8, #10, #12, #14, and #16 under Rule 4.052(3). The documentation/demonstration <br />requited for SAE status is provided in Appendix 6-4, 2003 Exploration Program, Attachment <br />lA, Hydrologic Documentation for Small Axea Exemption. <br />It is anticipated that the active drill pad would have a topsoil berm along the up-gradient <br />perimeter that would serve to direct rvnoff from undisturbed azeas azound the outside of the pad <br />area. The remaining perimeter, except for access entry, would have an eazthen berm and ditch to <br />contain all runoff from a ]0-yr/24hr storm event. Details of the pad layout and sediment <br />control plan aze included in Appendix 6-7, 2003 Exploration Program. <br />Seneca Coal Company • P.O, Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-3707 . FAX (970) 276-3014 <br />