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Mr. Dave Berry SS~.pervisor Coal Program Ih:visiorz of Minerals and Geology Page 2 SCC affirms the Division's observation that the post-mine drainage channels at the Seneca II-W "A" pit and at Seneca II aze subject to designs currently in review pursuant to TR-45 (Seneca II-W) and TR-36 (Seneca II), yet most of the channels have already been constructed. SCC went forward with construction in order to improve drainage control to ultimately protect the hydrologic balance. We recognize the Division's obligation to assess the constructed channels in terms of the performance standazds, and if deficiencies aze found, they will be corrected in a timely manner. SCC trusts that that the Division's requirements pertaining to the slides at the Seneca II-W "A" pit high-wall and Pond 16A are adequately addressed in the TR-45 submittal If any deficiencies are noted that are not consistent with the Division's rules, SCC will correct them in a timely fashion. Other Compliance Related Projects SCC believes there may be a minor point of confusion regarding our response to the Division's concems about rill and gully erosion. With respect to the specific concern about erosion in thewicinity of the shnib establishment azea at Seneca II, we conducted considerable repairs this past field season that we feel satisfied the division's concerns. Two additional channels were constructed, and the Division Inspector agreed that continued monitoring of these channels would be warranted to evaluate their functionality. If monitoring results dictate modifications are warranted, SCC will make them at an appropriate time in conjunction with the Division's schedule. If this is not the Division's understanding, then please let us know and we will work to rectify the problem. With respect to any other statements we made about rill and gully repair, our remarks were made in the context of future rill and gully development. Policy mandates we continue rill and gully inspections at these mines, and repairs will be scheduled and implemented as appropriate, and in conjunction with your inspection personnel. SCC is a bit confused by the Divisions remazks about the slide at Pond 012, but we think this issue can be clarified and resolved herein. We provided a partial response in the October 26, 20041etter that stated in pertinent part that "Pond 012 was originally over excavated to remove some very soft alluvium in the bottom of the drainage. Removal of this material in the azea of the pond removed a `toe buttress' and allowed the alluvial steep north drainage side slope to slump. Haul Road "D" was built above the slump area just after Pond 012 was built. The haul road berm was built over fill material, which added load the unconsolidated material causing additional slumpage/slides. The azea has been regraded more than once and appears stable after each regarding effort, however during subsequent spring mnoff/wet seasons the area slumps more. The haul road has since been abandoned and only a ditch remains; however the unconsolidated material below the ditch has not been totally stabilized. In order to achieve the minimum recommended 3H:1 V slope the area would require loading of the unstable toe of the slope above the pond or significant cutting into the existing ridge creating additional material for disposal". Our contract registered Geologist, and company Professional Engineer both agree that the prudent approach in this case is to monitor the situation, and comply with the reclamation schedule outlined in TR-25. That is, delay final stabilization of the slope to the Division's standard until SCC can implement the reclamation plan in TR-25. While this will take time, SCC does not foresee any off permit environmental damage risk that can occur in the interim. With regard to maintaining the survey stakes at the toe of the slide, we continue to experience the age-old problem of the deer and elk having an affinity for knocking over any stakes we set out. We ask the Division to accept that the survey line has been established for an extended period and is registered electronically, and has shown no movement during periods when there was movement upslope, of late. However, SCC will re-estabhsh the stake line immediately.