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Pond 016 Slide Remediation Plan <br />Page 9 <br />on vegetation cover greater than or equal to 70%. The newly submitted design for TR-73 <br />uses a "slow" response time for all vegetated areas (both reclaimed and undisturbed) and <br />a "medium " response time for the disturbed areas. Please revise the SEDCAD run using a <br />response time of "medium" for all reclaimed areas and `fast" for disturbed areas <br />associated with slide repairs. <br />Response: SCC used the SEDCAD4 Design Manual and User's Guide (7th printing-December <br />2008), Unit Hydrograph Response Shape, to estimate the response time based on ground residue <br />cover >75% = "slow". However, SCC has revised appropriate subwatershed response times to <br />comply with your request. <br />32. During the review process for SL-3, the Division identified postmining channels <br />constructed on the ground that do not have corresponding approved designs in the permit <br />application package. The figure below indicates the drainages (highlighted in red) in <br />question. Please either provide designs for the drainages or indicate where design <br />information can be located in the approved permit application package. <br />Response: The channels identified are a result of rill and gully repair conducted annually. It <br />was agreed upon in the past (with DRMS inspectors) that short gully forming areas could be <br />remediated by constructing undesigned lined or unlined channels to prevent on-going <br />remediation year after year. Based on the small watershed areas associated with these problem <br />areas, the resulting fix is channel that is over-constructed for the volume of resulting flow. <br />Therefore we would ask that this practice be continued for rill and gully remediation without <br />requiring design and approval. <br />If there are further questions, please contact me. <br />Sincerely <br />Roy A. Karo <br />Reclamation Manager <br />Seneca Coal Company <br />enclosure(s) <br />cc: Foster Kirby (OSMRE) <br />Jennifer Maiolo (BLM) <br />Seneca Coal Company* P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5219 • FAX (970) 276-5222