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coalN Company Seneca Coal Company <br />June 10, 2008 <br />Mr. Dan Mathews <br />Division of Reclamation, Mining and Safety <br />101 South 3=d, Suite 301 <br />Grand Junction, CO 81501 <br />(970) 243-1571 <br />Yoast Mine_P_ermit No. ,G94-082_ <br />NOV CV-2008-001: Abatement Step 2 <br />Mr. Mathews, <br />Seneca Coal Company (SCC) is providing information regarding Abatement Step 2, as stated in the "Attachment to <br />NOV CV-2008-001". <br />Step 2: No later than June 30, 2008, provide a complete technical revision application, which will include a slide <br />remediation plan prepared by a qualified geotechnical engineer. The remedial plan will identify and assess the <br />factors that contributed to the failure, will include specific remedial measures to be implemented to repair the slide <br />and effect compliance with the applicable requirements of Rule 4.14, and shall include a geotechnical stability <br />analysis demonstrating that the remedial plan will result in a final slope that will comply with Rule 4.14.2(1)(b). The <br />application will also address both short term and long term measures that will be taken to provide adequate <br />sediment controls in the Pond 12 watershed, consistent with long term mass stability of the failed slope. Short <br />term measures may include cleanout of Pond 12, if the geotechnical report demonstrates that such cleanout can be <br />accomplished without compromising slope stability. The application will include a schedule for implementation of <br />the slide remediation plan, including the short term and long term sediment control measures for the Pond 12 <br />watershed. <br />SCC has developed the following responses to each of the points/tasks mandated in the Step 2 Abatement <br />requirements. <br />a) No later than rune 30,_2008, provide a complete technieal revision application, which will include a slide remediation plan prepared ~ <br />by a qualifiedgeotechnica!engineer. <br />Response: The Yoast Mine is located in mountainous terrain on the western slope of the Rocky Mountains in <br />Colorado at an approximate average elevation of 7,700 feet. At these elevations the ground conditions remain wet in <br />the drainage bottoms throughout the spring and early summer (probably into July especially given the extreme snowfall <br />experienced over the 2007-2008 winter season). Equipment, such as that needed to evaluate the root cause of the <br />situation, cannot even access the area until considerable drying/dewatering has occurred. <br />SCC has retained a qualified geotechnical engineering firm to conduct a slide evaluation and geotechnical investigation <br />of the Pond 012 area. Following is the proposed scope of work to conduct the evaluation and investigations: <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-6219 • FAX (970) 276-6222