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T R44, Kidgeline Disturbance Area SAE <br />Response to Comments <br />pa <br />• ge 2 <br />2. The proposed sumps would in effect be small impoundments. Please provide a typical sump des gn drawing <br />and include narrative stating that the sumps would be subject to P.E. construction <br />certification and annual certification, quarterly operator inspections, and other requirements <br />ofRule 4.09.9. <br />Response: Please see response to Comment 4. <br />3. Because the sumps would depend on storage to control runoff; the design event should be the 25year, 24-hour event, <br />pursuant to Rule 4.05.9(2)(e), rather than the 10year, 24-hour event. Please amend the application <br />accordingly. <br />Response: Please see response to Comment 4. <br />4. As an alternative to the impoundment sumps, and to avoid the associated impoundment design, certification, and <br />inspection requirements listed in Items 2 and 3, above, a design approach utilising some type of sediment filtration <br />structures might be considered. Conceptually, this approach would utilize a series of properly sized diversion berms or <br />dips to route flow off of the ridgeline to the north, along with appropriate sediment filtration structures for each point of <br />diversion (perhaps some combination of rock checks to slow the flow and silt fence or straw wattles to filter sediment). <br />• Response: SCC has considered the Division's suggestion and has redesigned the drainage configuration for <br />this temporary SAE area. In general the area will be regraded to remove existing ditches, water bars and the <br />remnant Postmine Channel YPM-23. Runoff control will be accomplished by installing wattles, silt fence or <br />other similar interim methods to provide sediment and runoff control. The revised plan is attached for the <br />Division's review and approval. <br />Attached are revised/updated material and insertion instructions. Two copies of this response have been sent <br />to you at the Grand junction office and a third copy has been sent to the Division's Denver office. Should <br />you or any other member of the Division have questions regarding the information, please contact me at <br />(970) 276-5227 or (970) 846-3648. <br />Sincerely, <br />Roy A. Karo <br />Reclamation Manager <br />Seneca Coal Company <br />enclosure(s) <br />cc: <br />John Husband (BI.M) <br />0 Carl Johnston (OSMRE) <br />Sandra Brown (DRMS-Denver) <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5217 • FAX (970) 276-5222