REP40584

• Permit No: C1982057
• IBM Index Class Name: Report
• Doc Date: 11/22/2004
• Doc Name: 2003 ARR Response to Comments & Revised ARR Form
• From: Seneca Coal Company
• To: DMG
• Permit Index Doc Type: Annual Reclamation Report
• Media Type: D
• Archive: No

E
S ~/ ~~~
November 18, 2004
Seneca Coal Com
REC(~IV/'E®
Daniel Mathews
Division of Minerals and Geology NOV 2 2 2004
101 South 3'a, Suite 301
Grand Junction, CO 81501 Division of Minerals and Geology
[phone]
RE: Annual Reclamation, Revegetation, and Wildlife Reports for 2003
Response to Comments
Dear Mr. Mathews,
SCC has received your comment letter of Apri122, 2004 regarding the 2003 Annual Reclamation Report.
Attached please find two (2) copies of revised and/or additional information addressing your comments and
requests. A third copy has been 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.
Annual Reclamation Report
Please submit an amended version of the 1 page report form with the GPRA "Acreage fu active
mining areas"figure corrected (262.34rather than 647.55).
Response: Please replace the attached corrected form in your copy of the 2003 ARR.
Z 2001 and 2003 annual refiorts indicate that no .pail monitoring in accordance with ibe spoil monitonng plan .was conducted
in 2002 or 2003. The 2003 apart doer indicate that pail suitability monitoring will be conducted during the 2004 field
season, and references spoil sampling in the Lennox coal outcrop area and the graded lY/adge Spoil This irsue was addressed
in comments 7 and 8 of our December 22, 2003 Midterm Permit Review letter. Certain discrepancies ident~ed in those
review comments will need to be resolved to ensure that pail sampling it conducted ar required in 2004 and subsequentyears.
Response: In June of 2004, SCC collected a significant number of spoil samples at twenty-five locations
within the recently regraded portions of the "A" and `B" pits. The analytical results from this sampling effort,
evaluation of the results, and mitigation plans (if needed) will be included in the 2004 Annual Reclamation
Report. SCC had intended the 2004 sampling effort to include locations within the Lennox Coal outcrop area
graded in 2002 in the northeast area of the "D" Pit, but sample collection was inadvertently missed in this area.
Another sampling effort is scheduled for the Fall 2004, but due to soil specialist's schedule this effort has not
been completed as of 11-18-04. Within the next four weeks or as soon as weather permits in 2005, SCC will
collect overburden samples from an appropriate number of locations in the Lennox Coal outcrop area of the
"D" Pit. Analytical results from these samples wilt be reviewed and evaluated, and mitigation plans developed
and implemented if needed prior to the end of 2005. Concurrently, SCC will submit the analytical results,
evaluations, and any mitigation measures that may be needed to the DMG in 2005.
Future annual reclamation reports will reieience the currently approved spoil/highwall reduction area
monitoring and mitigation requirements, including the associated and required data and evaluations.
Seneca Coal Company • P.O. Box 870 • Hayden, Colorado 81839
Telephone [phone] • FAX [phone]