2008-12-31_REVISION - C1980005

• Permit No: C1980005
• IBM Index Class Name: REVISION
• Doc Date: 12/31/2008
• Doc Name: Response to Adequacy Review
• From: Seneca Coal Company
• To: DRMS
• Type & Sequence: SL3
• Email Name: MPB
• Media Type: D
• Archive: No

.S Coal /V ny Seneca Coal Company
December 22, 2008
Mr. Mike Boulay
Division of Minerals and Geology
101 South 3rd, Suite 301
Grand Junction, CO 81501
RECEIVED
0F_C 3.1 2000
D`v„w;101 o'eciamation.
Mining and Safety
RE: Seneca II Mine Phase II Bond Release Application (S1,3)
- Response to-Adequacy-Review
Dear Mr. Boulay,
Seneca Coal Company (SCC) has reviewed your adequacy review letter dated December 18, 2008 regarding water
quality documentation for the SL-3 Phase II bond release request. We are providing the following response as
documentation and clarification to the untimely last minute comments.
1. Please provide the actual mater quality data and sample locations for the background level information referenced in the water quality
demonstration on page 15 of the bond release request, and provide an actual comparison of TSS monitoring results that reflect pre-
mining conditions versus the reclaimed post-mine conditions to show compliance with Rule 3.03.1(3)(b).
Response: Attachment F of the Phase II Bond Release Request (SL-3) provides recent (2003-2007) data for Fish
Creek Site SSF1l (upstream of the confluence of the Pond 004 and 008 tributaries) and Grassy Creek Site SSG1
(upstream of discharges from Pond 002). The locations of these sites are provided with this letter on the attached maps
Seneca Coal Company General Location, and Seneca II Mine General Location.
Rule 3.03.1(3)(b) states:
No more than sixty (60) percent of the bond shall be released so long as the lands to which the release would be applicable are
contributing suspended solids to stream flow or runoff outside the permit area in excess of premining levels as determined by baseline data
or in excess of levels determined on adjacent non-mined areas; until soil productivity forprime farmlands has returned to equivalent levels
ofyield as non-mined land of the same soil type on the surrounding area under equivalent management practices as determined from the
soil survey performed under 2.04.12 and 2.06.6 and the success determination methodology of 4.25.5(3)(a); or, on alluvial valley floors,
until the essential hydrologic functions and agricultural productivity have been reestablished
Seneca chose the approach of using data from "adjacent non-mined areas", as opposed to using "baseline data" because
no baseline data exists for Pond 002 (this area was mined prior to the regulatory requirements for the collection of
baseline hydrological data). Seneca feels that this approach should have been considered sufficient. However, in
response to your letter, Seneca offers the attached additional evidence to support the information previously presented
in SL-3.
In the case of Pond 002, data from an additional upstream monitoring site, SSLG5, is provided on attached page 3.
This site is located on Little Grassy Creek upstream of Pond 002 (see the maps provided here). The timeframe for this
water quality statistics report is the same as that for Pond 002 in the SL-3, 2003 to 2007. Review of this upstream data
indicates a mean TSS concentration of 65.6 mg/1 and a maximum concentration of 106 mg/l. Both of the values are
Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639
Telephone [phone] • FAX [phone]