2010-10-12_REVISION - C1982057 ‎(4)‎

• Permit No: C1982057
• IBM Index Class Name: REVISION
• Doc Date: 10/12/2010
• Doc Name: Response to Adequacy Comments Round 3
• From: DRMS
• To: Seneca Coal Company
• Type & Sequence: TR68
• Email Name: SLB
• Email Name: SB1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203 COLORADO
Phone: [phone] DIVISION O F
RECLAMATION
FAX: [phone] MINING

SAFETY
Bill Ritter, Jr.
Governor
October 12, 2010
Mike King
Executive Director
Mr. Roy Karo
Loretta E. Pineda
Seneca Coal Company, LLC Director
37796 Routt County Road 53
P.O. Box 670
Hayden CO 81639
RE: Seneca II-W Mine (Permit No. C-1982-057)
Technical Revision Application No. 68
Permanent Light-Use Road Documentation
Response to Adequacy Comments - Round 3
Dear Mr. Karo:
The Division has reviewed the information submitted September 29, 2010 by Seneca Coal Company
(SCC), in response to our September 7, 2010 adequacy review letter for TR-68 at the Seneca Il-W
Mine. The September 7, 2010 letter identified three remaining concerns with the revision application.
The information provided by SCC satisfied two of our adequacy concerns, and we were able to find
documentation available at the Division to address the remaining issue. Therefore, the Division will
issue a proposed decision to approve your technical revision application. We do, however, believe it is
necessary to clarify the grounds on which the Division is basing its decision to approve retention of
Light-Use Road LU-1B.
At the request of the Division, SCC provided information to support SCC's contention that the easterly
portion of LU-1B existed prior to mining. SCC referred the Division to Exhibits 9-1 and 13-1, with
photo date bases of July 1989 and June 1990, respectively. The version of Exhibit 9-1 on file at the
Division did not include a photo base (only contour lines, and the road is not apparent), so we could
not use that map to verify existence of the road. Since our records indicate that mine related
disturbance at the site commenced prior to 1990, the photo base of Exhibit 13-1 would not positively
establish pre-mine existence of the road. We were, however, able to locate a May 10, 1983 series of
aerial photographs that depict the area in question. On those photos, it is clear that the easterly portion
of LU-1B did exist prior to mine related disturbance, so we concur with SCC's contention that this was
an existing road and would therefore be exempt from the requirement that the grade not be steeper than
10%.
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines
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