2008-11-19_REVISION - C1982057

• Permit No: C1982057
• IBM Index Class Name: REVISION
• Doc Date: 11/19/2008
• Doc Name: Response to Comments
• From: Seneca Coal Company
• To: DRMS
• Type & Sequence: TR61
• Email Name: DTM
• Media Type: D
• Archive: No

TR-61, Backfrlling and Grading Schedule and
Midterm Permit Review
Page 5
Both of these springs were in an area that was mined out. The Friederich Spring #1 is indeed the same as the
Seneca II-W Spring S-49. The two (2) Friederich Springs had a total of 0.066 cfs (15 gpm) of water righted
for livestock watering. Water flowing into Seneca's Pond 016, with an average flow of 56 gpm, will be used
to replace the springs water rights. Page 11 of Tab 16 has been revised to indicate this.
In an issue related to this area, Seneca had previously committed to the Division to address in the permit the
abandonment of the failed W-24 series wells below Pond 016A and to commit to monitoring the spring
(Spring S-50) that issues from the french drain at this site. These issues are addressed on Page 11 of Tab 15,
Table 1 in Appendix 15-3a and Page 15-3a-11.
4. On August 4, 2008, the Division received a July 29, 2008 addendum to the 2008 Rill and Gully Survey, which described
the scope of work forgeotechnical investigations to be performed in association with the `Shrub Plot Slide "and `Pond 016
Slide ",- slope failures that occurred in the spring of 2008. Please provide an additional Rill and Gully Survey
addendum upon completion of the geotechmcal investigations, for Division review and
acceptance, prior to initiation ofrepair work. The further addendum should contain the NWCC
final geotechnical report and the selected remedial plan for each slide.
Response: SCC will submit, for review and approval, the final geotechnical report and selected remedial plan
for each slide.
.5 Certain updates to the remSetation plan are warranted. Specifically, the woody plant density standard for aspen planting
areas needs to be defined, and the Appendix 22-3 `Aspen Study Plan "needs to be updated to incorporate the final study
report for the original study plots, and to describe the on going aspen/ servicebery establishment studies being conducted in
cooperation with the Forest Semee Rocky Mountain Research Station. Because the aspen planting areas include seeding and
planting with woody shrubs in addition to aspen, it would seem reasonable that the concentrated aspen planting are as include
both a total woody plant stem density standard and an aspen stem density standard. A total woody plant density of 1000
stems per acre, with at least 150 aspen stems per acre may be an appropriate standard for these concentrated planting sites.
Please address these issues and amend the appropriate sections of Tab 22 as warranted.
Response: SCC is conducting monitoring and analyses to determine appropriate and reasonable woody
plant density standards. A revision to update Tab 22 will be submitted for approval prior to Phase III bond
release requests.
Enclosed are two (2) copies of the revised materials, a third copy has been sent to the Denver office also
addressed to you. If there are any questions, please contact me at [phone] or [phone].
Sincerely,
1
Roy A. Karo
Reclamation Manager
cc: Carl Johnston (OSMRE)
John Husband (BLM)
Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639
Telephone [phone] FAX [phone]