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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 COLORADO <br />Denver, Colorado 80203 D I V I S ION OF <br />Phone: (303) 866-3567 RECLAMATION <br /> MINING <br />FAX: (303) 832-8106 <br /> SAFETY <br /> Bill Ritter, Jr. <br /> Governor <br />2010 <br />tember 7 <br />Se Mike King <br />, <br />p Executive Director <br />Roy Karo Loretta E. Pineda <br />Director <br />Seneca Coal Company, LLC <br />37796 Routt County Road 53 <br />P.O. Box 670 <br />Hayden CO 81639 <br />RE: Seneca II-W Mine (Permit No. C-1982-057) <br />Technical Revision Application No. 68 (TR-68) <br />Permanent Light-Use Road Documentation -Adequacy Response Review <br />Dear Mr. Karo: <br />We have reviewed your May 13, 2010 response to our preliminary adequacy review letter regarding <br />Technical Revision No. 68 (TR-68). With the exception of Item 4 from our January 5, 2010 letter, <br />your response adequately addressed our concerns. <br />4. The Division's original concern was with the overall grade of the LU-1 roadway exceeding <br />10%. We noted that, with the exception of pre-existing roads, Rule 4.03.3(3)(a) specifies that <br />the overall grade for a light use road shall not be steeper than 10%. We further suggested that <br />SCC separately designate sections of the road that are pre-existing in an effort to clarify what <br />criteria would apply to each section. SCC designated the road in sections (LU-1, LU-IA, and <br />LU-1B), as requested, and clarified which sections of the road were pre-existing. SCC also <br />noted that their request for permanent retention of the westerly section of LU-113 had been <br />withdrawn because SCC had not been able to find photo documentation that the westerly <br />section existed prior to construction of the power line. These actions resolve the gradient issue <br />for sections LU-1, LU-1A, and the westerly portion of LU-1B. It is not clear, however, <br />whether SCC has any documentation that the easterly portion of LU-113 existed prior to <br />construction of the power line, as is noted in the text of page 20-2.2. Since it appears that the <br />overall grade of that segment exceeds 10% (our estimate, based on the information provided by <br />SCC is that the overall grade for the easterly segment of LU-1B is 10.8%), such documentation <br />will be necessary. <br />Please either provide additional information to indicate that the overall grade of the <br />easterly portion (the portion proposed for permanent retention) of LU-1B does not exceed <br />Office of Office of <br />Mined Land Reclamation Denver • Grand junction • Durango Active and Inactive Mines