REV105579

• Permit No: C1982057
• IBM Index Class Name: Revision
• Doc Date: 1/27/2004
• Doc Name: Response to Comments
• From: Seneca Coal Company
• To: DMG
• Type & Sequence: MR55
• Media Type: D
• Archive: No

E~~A
Coal Company
Seneca Coal Com
January 22, 2004
Mr. Dan Mathews
Division of Minerals and Geology
101 South 3~, Ste 301
Grand Junction, CO 81501
(970} 242-5025
RECD@l~i~~
JAN c r 2004
D19isinn of Minerals and 6eolog~~ Ch(MG~ ~u.rt C~iOtV
4ec,e~red ~
RE: Seneca II-W Mine Permit C-82-057
Minor Revision 55 (MR-55), Response to Comments
Dear Mr. Mathews,
Enclosed please find two (2) copies of revised and/or additional information addressing the
comments and requests in your January 8, 20041etter regarding MR-55. A third copy has been sent
to the Division's Denver office also addressed to you. The responses to each of your comments and
requests are provided below and are numbered accordingly.
In the rover letter, you reguert extension afAbatement Item 2 Ueld implementation) from February 19, 2004
until June 1, 2004, due to the fact that winter conditions will preclude abatement by February 19. In my
judgment„ the justification presented in your cover letter doer constitute Good cause far extension of the 90 day
abatement deadline, pursuant to 5.03.2(2)(t)(iv). I will fonvard a retammendatian to my supervisor and the
director that an extenrron reguert be granted, pursuant to 5.03.2(2)(e). Note that, pursuant to 5.03.2(2)(gJ, no
abatement exxtenrron can exceed 90 days In length. As such, my recommendation will be that the
abatement deadline be extended to May 19, 2004. Note that, if weather conditions
continue to prevent abatement by the extended deadline, you have the option of
requesting a further extension prior to expiration of the initial extension, in accordance
with the procedures of5.03.2(Z)(e).
Response: Thank you for your concurrence and recommendation.
2 The Gully Repair Map (Appendix 22-4) properly distinguishes behveen Bullied drainage channels that will need
to be repaired to conform with approved designs (dashed green), and hillslopegullies or non-drainage channel gullies
that wit! be "regarded and topsoiled ar necessary" (solid blue). Bared on the repair map and field obreruation, at
least one of the solid blue gully segments would appear to more properly be considered a drainage channel gully.
Specifically, the third "solid blue"gully from the south, in the 1997 reclaimed parcel would teem to be to be an
extension of the channel fork that pacer immediately to the north of the island of undisturbed habitat. Due to the
high gradient and cantentrated flow along this segment, it would appear that grading and topsailing may not be
appropriate or su~cient, and that tiptop installation may be neterrary. Please address this concern and
amend the plan map as appropriate.
Response: This is the upper portion of Channel 006-E2. This portion of the Postmine Channe] will
be repaired in conjunction with the re-design addressed in your December 22, 2003 comments on
TR-45 (Comment 77). However, the plan map has been amended as requested.
Seneca Coat Company • P.O. Box 670 . Hayden, Colorado 81639
Telephone [phone] • FAX [phone]