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SE Seneca Coal Company <br />November , 2008 <br />Mr. Daniel Mathews ID <br />Division of Reclamation, Mining and Safety , <br />101 South 3`d, Suite 301 <br />Grand Junction, CO 81501 NQ? '??' awo?. <br />(970) 242-5025 v?m <br />®`v?s?oru•?d Byfe?! <br />RE: Seneca II-W Mine (Permit C-1982-057) <br />Technical Revision (TR-61), Bacldrlling and Grading Schedule and <br />Midterm Adequacy Review - Response to Comments <br />Mr. Mathews, <br />Seneca Coal Company (SCC) has reviewed your adequacy comment letter of September 24, 2008 and the <br />Mid-Term Permit Review (dated September 29, 2008), specifically Section IV - Midterm Adequacy Review <br />and Request for Revision. <br />Upon review and consideration of the Division's comments and concerns regarding SCC's postmining <br />topography and drainage, it appears that there is confusion between what is proposed for permanent <br />structures and the required timing of approval prior to a Phase I bond release application. The structures <br />presented on Exhibit 20-2 indicate the postmining configuration and permanent structures that SCC would <br />like to leave at the time of Phase I bond release. SCC understands that requests and approvals are required <br />from various entities, including DRMS, at the time the Phase I bond release application is submitted <br />otherwise bond release can not be requested for that particular area. SCC will submit appropriate revisions to <br />update the permit as requests for retention of the various structures indicated on Exhibit 20-2 are received. <br />After consideration of the concerns and requested revisions, SCC has decided to combine both comment <br />letters into one (1) technical revision since the comments primarily affect the postmining topography and <br />bond release. Following are responses to those comments. <br />September 24, 2008 Comments (IR-61 Comments <br />1. Does noised Table 19-1 include TAHR acreage? What is the prvmposed deadline (and justification) for TAHR backfilling <br />and grading? Please amend the Tab 19 text and Table 19-1 to address these questions. <br />Response: Table 19-1 did not include the TAHR acreage. A revised Table 19-1 is included in this package <br />with a footnote addressing the TAHR. <br />The text in Tab 19 has been update to include a proposed backfill and grading schedule for the TAHR. <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5219 • FAX (970) 276-5222