REV98159

• Permit No: C1994082
• IBM Index Class Name: Revision
• Doc Date: 9/30/1999
• Doc Name: SCC RESPONSES ADEQUACY REVIEW
• From: SENECA COAL CO
• To: DMG
• Type & Sequence: PR1
• Media Type: D
• Archive: No

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S CoelCompany Seneca Coal Company
September 29, 1999
Mr. Michael Boulay/Ms. Sandra Brown
RECEIVED
Division of Minerals and Geology SEP 3 0 ~ggg
1313 Sherman Street, Room 215
Denver, CO 80203-2273 Division of Minerals 8 Geol
[phone] oQy
RE: YOAST MINE -COMMENT RESPONSES -PROS, UPDATED LIFE-OF-MINE
PLANS FOR MINING AND RECLAMATION ADEQUACY REVIEW
Deaz Mr. Boulay/Ms. Brown,
Enclosed you will fmd three (3) copies of revised and/or additional infom~ation addressing the two
adequary comments in Ms. Brown's September 2, 1999 lever and the one comment in Mr. Larry
Routten's September 8, 1999 letter with regard to the application for PROl to the Yoast Mine Permit
C-94-082. Responses to each of the comments aze provided below and are numbered according co
the original submittals.
PROTECTION OF
Comment 6 (Original Comment) SCC asserts Jxcr tlx field ~ Stctiot 18 upsttean for[sicJ dr ftmrrr
Saar C~k Reserwv is not an alGtcial tttUey floor, ~ lm~fy on dr fact that irrigatitn obsertal at dxu site in
19957eas lxceg danewitlaz¢ prolrr tex~r rights Phase note that, m order for dr Diuisicc to feed that this aria
is not an alluvial ?alley floor; ue mould rtes[ euitlat~ tlwt it nts2t nor of dr niter • . nod in Rule
2.06.8(3)(c)(IJ(BJ. 71x Yoast pemnt an,ettfy caduates that dx ftdd is sufiirr:gareL If thi< ,. n:ce, dx fred
arnuld mcet the rtgtrlatary defmitioc ofan alluvial ~Y ffaor coder subpxragrapti 111 of the ride ciuxi aEoce
SCCmaywish to mcsder ansti~vgone piece of mfonrx¢ia: tehidi dr Diursioc does not amauly hate Rule
1.04(142) defaces tm~olitlatal stmmrc (aid delusits, reJirdi am a rrarssary part of an a!luuinl xa1/eyHorn; as
f~ plaacs and terra¢s in tlx [Doer naxdes of zu(leys vherh m main dmaracs tlzxt am gmnur tlxm 3 frrt vt
&mkfull ieadt<i and greim rlxm 0.5 feet in bartkfwll depdz At this tiny, the Druirun does not know f'tix
P°rtiot of Safe C,~k near dr field vi Savoc 18 mats these criteria.
(Response submitted 6/25/99-AVF and Hydrologic Responses) The small hay field located in
Section 18 upstream from the breached Sage Creek Reservoir has not been fotmal}y been designated
as an AVF, but appears to possibly qualify on the basis of limited flood irrigation. Designation as an
AVF is, however, questionable since this is an "upland area", the existence of unconsolidated stream-
laid deposiu has not been established, water availability for flood imgation is limited, and the size and
inherent productivity of the subject azea relative to support of agricultural activities is marginal, at
best. Based however, on the potential for this area to be designated as an AVF, further investigation
of the property was initiated by Mr. Roy Kazo (SCC Reclamation Manager) and Mr. Scott Dillon
(Agrinrltural Economist). Mr. Kato and Mr. Dillon interviewed the landowners, Mr. Gary and Mrs.
Mary ~'alora, on May 13, 1999 and completed a survey of their existing agricultural practices reL~tive
to the subject lands. The interview included discussions regarding current land use and land
management prattices, and farm operation economics. Findings from the interview and survey aze
summarized below.
Seneca Coal Company • P.O. Drewer D • Hayden, Colorado 61639
Telephone [phone] • FAX [phone]