2008-12-05_REVISION - C1994082

• Permit No: C1994082
• IBM Index Class Name: REVISION
• Doc Date: 12/5/2008
• Doc Name: Response to Comments
• From: Seneca Coal Company
• To: DRMS
• Type & Sequence: TR38
• Media Type: D
• Archive: No

,41S coalNconwany Seneca Coal Company
December 3, 2008
Mr. Dan Mathews
Division of Reclamation, Mining and Safety
101 South 3`d, Suite 301
Grand Junction, CO 81501
[phone]
RE: Yoast Mine Permit No. C-94-082
Technical Revision (TR-38) - Pond 012 Slide Remediation Plan
Response to Comments
Mr. Mathews,
RECEIVED
uw ;3 5 2000
Division of a d Sa ety n,
Mining
Seneca Coal Company (SCC) has reviewed the Division of Reclamation, Mining and Safety (DRMS) letter
dated November 5, 2008. SCC has consulted with our accredited geotechnical consulting firm Northwest
Colorado Consultants (NWCC) and has developed the following responses to your concerns.
1. The NWCC report was submitted as a `stand-alone " document for insertion in a permit attachment. The report contains
consultant recommendations concerning further monitoring, evaluation, and possible remediation approaches. However, the
submittal did not provide commitments and schedules from SCC, other than the generalized cover letter•reference to submit
`follow-up recommendations and plans....once the remaining evaluations and assessments have been completed"
Please provide the Division with commitments addressing the proposed schedule ofmonitoring,
data collection, and additional field investigation, a specif"rc schedule for submittal of
remediation plan designs (designs to be provided within a future TR application), and proposed
schedule for construction ofany approved reme&atron measures. This information should
reflect the findings and recommendations of the NWCC report, but should be presented as SCC
peraut commitments, within appropriate permit narrative or attachment sections, separate from
the NWCC report.
Response: NWCC will be taking measurements of the groundwater levels and observing the condition of
the PVC casing in the test holes, as well as the soil movement occurring at the site during the month of
November 2008, as well as on a monthly basis through the anticipated peak runoff period from April 2009 to
July 2009. A supplemental subsurface investigation, which included the drilling of two new test holes at the
site, was completed in November 2008. NWCC anticipates that the final report, as well as plans and
recommendations for the remediation of the slide at the site will be available by August 3, 2009.
2. The application did not specifically address the measures that have been or will be taken to ensure both short term and long
term sediment control compliance for the Pond 12 watershed, as specified in the NO V CV-2008-001 Abatement Step No.
2. We air aware that certain "on the ground" and permitting steps have been taken to address these issues, including
completion of a sediment survey for Pond 12, construction of new Pond 12A, and inclusion of proposed sediment control plan
Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639
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