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STATE OF <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />7313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />January 28, 2004 <br />Roy A. Karo, Reclamation Manager <br />Seneca Coal Company <br />P.O. Box 670 <br />Hayden, Colorado 81639 <br />RE: Seneca II-W Mine (Permit C-1982-057) <br />MR-55 (Rill and Gully Plan) <br />Dear Mr. Karo: <br />We have reviewed your submittal dated January 22, 2004, which was in response to our <br />January 8 review letter regarding MR-55. We are concerned that referenced repair time <br />frames and somewhat subjective gully repair commitments of the amended plan are not <br />entirely appropriate, given that the plan addresses work to be done to abate a notice of <br />violation. A degree of specificity and rapid compliance is warranted, due to the constraints <br />imposed by the enforcement process. <br />We request that the following modifications be made to the repair plan map Notes: <br />1. Please insert language stating that: At a minimum, in addition to repairs based an <br />the subjective criteria described in these notes, all hill-slope or non-defined channel <br />rills and gullies within the delineated Potential Rill and Gully Areas /outlined in blue/ <br />will be regraded, topsoiled, and seeded if they exceed 12 inches in depth. <br />2. The final bulleted paragraph of the Notes section describes the repairs to be <br />conducted, and states that the work will be performed "during the'June-October <br />2004 Field Season". This would not appear to be in accordance with the <br />requirement of Rule 5.03.2(2)(e), that "the abatement period granted shall not <br />exceed the shortest possible time necessary to abate the violation". Please amend <br />the referenced paragraph to state that: The identified/evaluated rills, gullies, and. <br />contour ditches will be regraded, topsoiled, and seeded as necessary, in comp/lance <br />with the dead/ine speciried in NOV CV-2003-014 Abatement Step 2, as maybe <br />extended by the Division in conformance wlth Ru/e 5.03.2(2/(eJ and (g/. <br />COLORADO <br />DIVISION OF <br />MIN SRALS <br />GEOLOGY <br />REC LAMATION•MI NING <br />SAf ETY•SCIENCE <br />Bill Owens <br />Governor <br />Greg E. Walther <br />Executive Director <br />Ronald W. Cottony <br />Didsion Director <br />Natural Resource Trustee <br />Office of ~ Office of ~oloraoo <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />