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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 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />May 31, 2011 <br />Roy Karo <br />Seneca Coal Company, LLC <br />P.O. Box 670 <br />Hayden CO 81639 <br />RE: Seneca II-W Mine (Permit No. C1982057) <br />Technical Revision No. 73 <br />Pond 016 Slide Area Remediation Plan <br />Second Adequacy Review <br />Dear Mr. Karo: <br />COLORADO <br />D I V I S I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta E. Pineda <br />Director <br />The Division has reviewed your responses to our preliminary adequacy review concerns for Technical <br />Revision No. 73 (TR-73) for the Seneca II-W Mine. We have the following comments on the <br />resolution of those items. <br />1. SCC's response provides additional details about the proposed construction sequence for the <br />backfilling of Pond 016A. This item has been satisfactorily addressed. The Division does <br />have one comment, however, regarding the final sentence of the response which reads, <br />"There will be no anticipated source of water for continued infiltration into the fill area." <br />While the reconfiguration of channels, as proposed with this revision, is intended to capture <br />and redirect the surface and subsurface flow entering the area of Pond 016, a more prudent <br />approach to design and construction would be to assume that water will inevitably find its <br />way into the fill. <br />2. SCC responds that NWCC will sample fill materials as they are being excavated from the slide <br />and placed in Pond 016A. Compaction testing during placement of the fill is a key part of the <br />process, but separate from the development of Standard Proctor curves. Moisture / Density <br />("Proctor") curves are developed in the laboratory prior to commencement of placement and <br />compaction. Curvos are developcd -for each separate typ^ of fill material for blend of <br />materials) likely to be used; each curve will have a specific maximum dry density and optimum <br />moisture content. During placement, accurate compaction results are dependent upon <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines