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TR-61, Backfilling and Grading Schedule and <br />Midterm Permit Review <br />Page 2 <br />2. The depicted alignment for the light use road across the upper portion of the reclaimed 016 watershed on amended Exhibit <br />19-1 di fers from that depicted on approved Exhibit 20-2. Based on site inspection and review of aerial photos, the <br />alignment depicted on Exhibit 20-2 appears to be incorrect. Please provide an amended Exhibit 20-2, unless <br />there is a satisfactory alternative explanation and remedy for the map discrepancy. <br />Response: Exhibit 20-2 has been updated to accurately depict the portion of road in question. <br />Exhibit 20-2, Postmining Topography and Drainage, has also been updated to include 5 additional permanent <br />culverts and 7 minor lined-channels. The additional culverts installed to supplement the approved road <br />drainage designs are the same diameter as the lesser number of inplace culverts originally approved and <br />therefore are more than adequate to handle the projected flows. The channels and culverts have been <br />installed to supplement approved drainage plan and to assist with the remediation of rills and gullys; therefore <br />no designs have been submitted for these drainage control structures. <br />There is one exception however, Culvert PM-16 that provides drainage from alongside the Oil Well Access <br />road and under permanent Road (A) has been designed and the SEDCAD model is included in this package. <br />Tables 13-5 and 13-7-1, Culvert Summary, have been updated to list all existing/permanent culverts. <br />3. The shop area grading deadline is listed as 2022 on amended Exhibit 19-1. However, the grading deadline for Sediment <br />Pond 006 vicinity is listed as 2012. We would note that, if Pond 006 is not maintained as a sedimentation pond after <br />2012, alternative sediment controls would need to be approved and implemented for the shop area disturbance until the shop <br />area is reclaimed and stabih.Zed. Please make note of this concern and ensure that proper sedimentation <br />controls are approved and installed for the shop area disturbance for as long as such controls are <br />required by Rule 4.05. <br />Response: SCC notes your concern; however this was simply an oversight. Exhibit 19-1 has been revised to <br />indicate an appropriate year, which conforms to Rule 4.05. <br />September 29, 2008 Letter - Midterm Penruit Review <br />1. Minor Revision No. 61 (MR-61) was submitted June 28, 2006, and included requests and documentation for various road <br />segments to be modified and retained as permanent structures for the postmining land use. The MR-61 review continued <br />without resolution until August6, 2007, when it was withdrawn based on a letter from Roy Karo of SCC dated August 1, <br />2007. In that letter, SCC indicated that a technical revision application addressing permanent structures to be retained for <br />the postmining land use would be submitted at a later date. <br />To date, the Division has not received a technical revision addressing retention of roads and/ or other facilities and structures <br />for postmining land use. In a MR-61 review letter dated April 5, 2007, the Division listed four items of concern (Items 7 <br />through 10), which addressed certain inconsistencies between permit narrative and map Exhibit 20-2 (Postmining <br />Topography and Drainage), with respect to final topography and retention of permanent structures associated with certain <br />roads, the shop area bench, and certain electrical facilities <br />Please submit appropriate map and narrative amendments addressing Items 7 through 10 of the <br />Apri15, 2007 letter. <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5219 • FAX (970) 276-5222