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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Rewurces <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />July 12, 2004 <br />Roy Karo <br />Seneca Coal Company <br />P.O. Box 670 <br />Hayden, CO 81639 <br />RE: Seneca II-W Mine (Permit No. C-1982-057) <br />Slide Remediation Plan and Future Regrading Considerations <br />Dear Mr. Karo: <br />COLORADO <br />DIVISION O F <br />MIN&RALS <br />GEOLOGY <br />0.EC lANATION•NINING <br />SAFETY•SCIENCE <br />Bill Owens <br />Governor <br />Russell George <br />Ezecutive Director <br />Ronald W. Cottony <br />Division DireROr <br />Natural Resource Trustee <br />Last week I forwarded to you Byron Walker's report on the slide areas at Seneca II-W, <br />based on our May site inspection. I also included a request that you take Byron's <br />recommendations under advisement in preparation of the remedial plan for the "A" Pit <br />highwall reduction slide area, the Pond 16A slide, and future steep slope operations and <br />reclamation. <br />With regard to the potential need to apply specific material handling measures to future <br />reclamation operations, possibly including use of rock drains and controlled compaction in <br />association with stability analysis, please refer to the requirements of Rule 4.14.1(2)(a) and <br />Rule 4,14.2(1)Ibl• The first rule requires that "all spoil shall be transported, backfilled, <br />segregated and compacted where needed to insure stability..." The second rule requires <br />that operators "backfill and grade to the most moderate slope possible, which does not <br />exceed either the angle of repose or such lesser slope as is necessary to achieve a minimum <br />static safety factor of 1,3". <br />The currently approved backfilling and grading plan in Tab 20 does not seem to specifically <br />address how compliance with these requirements will be ensured and demonstrated. Please <br />include appropriate modifications to Tab 20 as a component of the slide remediation <br />technical revision application, to ensure that future steep slope reclamation operations will <br />be conducted in conformance with these provisions. <br />Finally, please include within the revision application a commitment for implementation of <br />the remedial slide repairs (and full reclamation of the "A" Pit slide are~by no later than <br />October 15, 2004. <br />Sandy and I will be at the mine later this week, and we can discuss these matters at that <br />time if you have questions. <br />Sincerely, <br />Daniel T. Mat ews <br />Environmental Protection pecialist <br />Once of Office of Colorado <br />