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<br />sE iec Seneca Coal Company <br />September 29, 2010 RFCVID <br />Mr. Daniel Mathews OCT 012010 <br />Division of Reclamation, Mining and Safety piv*i©n <br />101 South P, Suite 301 mining a tleja'?on, <br />Grand Junction, CO 81501 <br />(970) 242-5025 <br />RE: Seneca II-W Mine (Permit C-1982-057) <br />Technical Revision No. (TR-68), Permanent Light-Use Road Documentation <br />Response to Adequacy Comments - Round 3 <br />Mr. Mathews, <br />Seneca Coal Company (SCC) has reviewed Ms. Susan Burgmaier's Adequacy Response Review letter <br />dated September 7, 2010 and has developed the following responses: <br />• 4. The Division's original concern was with the overall grade of the LU-1 roadway exceeding 10%. We <br />noted that, with the exception of pre-existing roads, Rule 4.03.3(3)(a) specifies that the overall grade <br />for alight use road shall not be steeper than 10%. We further suggested that SCC separately <br />designate sections of the road that are pre-existing in an effort to clarify what criteria would apply to <br />each section. SCC designated the road in sections (LU-1, LU-1A, and LU-1B), as requested, and <br />clarified which sections of the road were pre-existing. SCC also noted that their request for <br />permanent retention of the westerly section of L U-1 B had been withdrawn because SCC had not been <br />able to find photo documentation that the westerly section existed prior to construction of the <br />powerline. These actions resolve the gradient issue for sections LU-1, LU-IA and the westerly <br />portion of L U-1 B. It is not clear, however, whether SCC has any documentation that the easterly <br />portion of L U-1 B existed prior to construction of the powerline, as is noted in the text of page 20-2.2. <br />Since it appears that the overall grade of that segment exceeds 10% (our estimate, based on the <br />information provided by SCC is that the overall grade for the easterly segment of L U-1 B is 10.8%), <br />such documentation will be necessary. <br />Please either provide additional information to indicate that the overall grade of the easterly <br />portion (the portion proposed for permanent retention) of LU-1B does not exceed.10%, provide <br />documentation that the road existed prior to mine-related permitting and disturbance, or withdraw <br />the request for permanent retention of the L U-IA segment. <br />Response: If the Division will review Exhibits 9-1 and 13-1, (photo dates 7/1989 and 6/1990) there is <br />• evidence that the road segment LU-1B existed prior to mine related disturbance. <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5219 • FAX (970) 276-5222