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III IIIIIIIIIIIII III <br />999 <br />~~~ <br />S CFoaN omE p~' <br />Seneca Coal Company <br />Mr. Michael Boulay <br />Division of Minerals and Geology <br />1313 Shem~art Street, Room 215 <br />Denver, CO 80203-2273 <br />(303)866-3567 <br />January 19, 1999 <br />RECEIVED <br />RE: YOAST MINE (Permit No. C-94-082) PHC/AVF COMMENT~A~ 2 2 1999 <br />RESPONSES <br />Dear Mr. Boulay, Dli,~'Dn of Minerals 8 GeolOQy <br />Seneca Coal Company has reviewed your December 31, 1998 letter with regard to the probable <br />h}•drologic consequences and AVF issues concerning Sage Creek. Responses to Comments 1 <br />tluough 7 (of yotu Division's June 7, 1995 letter) are provided below, as requested. The revised <br />pages to the permit, referenced below, will be submitted at a later date along with the Sage Creek <br />Basin permit revision. <br />Comment 1. 77x ctndirsuvr stttiat of Attadarrart 16-3 ~on pages 16-3-7 and 8J appears to lx tle cwxG+sicvr of <br />tlx A VF study for d~ Serraa l/- lY~ ltilore. 71ii~ settimr n~s to Fe >g~ to address A VF's in lrydmlogic <br />mrorumirnria: •rrvilr tle Yarst hftite. Page 16.3-3 vrdrtdes a disaarion of HxC~twn Grdth tlxu mrtld !x deletal <br />Attachment 16-3 has previously been revised to address these issues. <br />Comment 2. 71x disacssicnu of tl~ "srrbirrigatellxry field" vs Section 18 on Sage Cr~k (p. 16-3-5; page 12 of <br />Tab 16J nary nil to /e reUisal to anrormt forJl«d imgatia: of d~ field, as disausal vt Iton I/I aline <br />The information on the Section 18 hayfield, originally supplied on page 16-3-5 (due to <br />subsequent revision this information is now on page 16-3-3) has been revised to mention flood <br />imgation. Page 12 of Tab 16 has likewise been revised. <br />The Yoast Mine alluvial Valley Floor Investigation Report (Tab 16, Attachment 16-3, page 20 of <br />the Golder Associates report) references the Soil Consen'ation Service's criteria that a <br />streantflow of 1 cfs is required to imgate 40 acres. The Section 18 hayfield is approximatel}' 13 <br />acres, which would require 0.325 cfs to imgate. Streamflow data for Site YS52 are provided in <br />Appendix 7-6 of Tab 7. This site is about 0.25 miles upstream of the hayfield. Review of these <br />data indicates that insufficien[ water for significantly beneficial imgation would occur aher May <br />or June. By July, an average of only 0.14 cfs, and by August an average of only 0.04 cfs, would <br />be available for imgation. These data, along with the consideration that the imgation diversion <br />here is not water-righted, leads Seneca Coal Company (SCC) to conclude that flood imgation <br />here is insignificant and does no[ warrant examination under Rule 2.06.8(4). <br />Comment 3. 71~e di~cussirnz of tl~ potentirdly imgatrt/ a falfa field in Secrim 30 s/wrr/d Fe reuisg! to address tlx <br />potential for flat? irrigation with ngard to tlx lii~[oric rrsertrir nr t/xu field (Ta(~ 16, pate 13; page 16-3-6, as <br />disac~sel in Itan IV aline. <br />The CDMG states, in Item IV of their June 7, 1995 letter, that there may be enough water now <br />to restore flood imgation to the hay field in Section 30, T6N, R87W. This statement was <br />Seneca Coal Company P.O. Drawer D 'Hayden, Colorado 81639 <br />Telephone (970) 276-3707 FAX (970) 276-3014 <br />