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Permit Revision No.2 <br />Response to Adequacy Comments <br />Page 4 <br />would become permanent features in the future (since they are already approved as <br />permanent). <br />Response: Page 2.05.3-1 has been revised as requested. <br />2.05.4(2)(e) <br />11. On page 2.05.4-2 of the PR-2 application volume, there is a subsection titled <br />"Revegetation Monitoring". The narrative within the section does not actually <br />address interim revegetation monitoring, but rather includes one brief paragraph and <br />a separate sentence at the end of the subsection that pertain to methods for <br />demonstrating revegetation success for bond release, and an additional paragraph <br />that pertains to revegetation chronology. Quantitative interim revegetation monitoring <br />at Seneca II has been phased out, as the emphasis has shifted to sampling for <br />demonstrations of success for Phase II and Phase III bond release. The revegetation <br />monitoring section of the permit application package was updated with TR-50 in 2009, <br />to reflect this shift in emphasis. The "Revegetation Monitoring" subsection heading in <br />the PR-2 volume should be deleted, along with the confusingly written 1St paragraph of <br />the subsection and the unnecessaryfinal sentence of the subsection. The second <br />paragraph of the subsection should be retained, under a subsection heading <br />"Revegetation Chronology ". Please amend the narrative as warranted. <br />Response: The narrative has been revised as requested. <br />12. The introductory paragraph to the subsection titled "2.05.4(2)(e)(vi) Determining <br />Revegetation Success " contains erroneous references to regulation sections 4.15.9 and <br />4.15. 10 that do not apply to the Seneca II permit area proposed in PR-2. Please delete <br />the erroneous references. <br />Response: The references have been deleted. <br />13. The third paragraph of the "Determining Revegetation Success " subsection includes <br />an unnecessary, confusing, and outdated reference to revegetation monitoring, which <br />would be conducted "in the third or fourth, ninth and tenth year following permanent <br />seeding....... The entire first sentence of the paragraph should be deleted; interim <br />quantitative monitoring is no longer required under the approved permit, and the 9th <br />and 10th year sampling reference is also dated (current regulations allow success <br />demonstration sampling in the final four years of the liability period, beginning no <br />earlier than year 9, as correctly noted in Appendix 13-13 of the approved permit). <br />Please amend the narrative as warranted. <br />Response: The narrative has been revised as requested. <br />14. Vegetation sampling bond release blocks, sampling methods, and associated statistical <br />procedures for demonstrations of revegetation success are currently addressed in <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5217 9 FAX (970) 276-5222