2013-07-29_REVISION - C1982057 ‎(14)‎

• Permit No: C1982057
• IBM Index Class Name: Revision
• Doc Date: 7/29/2013
• Doc Name: Adequacy Review No. 1
• From: DRMS
• To: Seneca Coal Company
• Type & Sequence: SL4
• Email Name: JLE
• 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
C O L O RA D O
D I V I S I O N o f
Denver, Colorado 80203
RECLAMATION
Phone: [phone]
M IN I NIN G
N
FAX: [phone]
SAFETY
July 29, 2013
John W. Hickenlooper
Governor
Roy Karo
Seneca Coal Company, LLC
Mike King
P.O. Box 670
Executive Director
Hayden, CO 81639
Loretta Pineda
Director
Re: Seneca 11-W Mine (Permit No. C- 1982 -057), Bond Release Application No. 4 (SL -4)
Adequacy Review No. 1
Dear Mr. Karo,
The Colorado Division of Reclamation, Mining and Safety (Division) wrote an adequacy review letter in regards to
the SL4 bond release application dated June 18, 2013. The Division received an adequacy review response letter
from your office on July 15, 2013. There are several outstanding issues that will need to be addressed prior to the
Division issuing a proposed decision for the SL4 bond release application. The adequacy items from the June 18,
2013 letter are listed below and italicized. A summary of Seneca Coal Companies (SCC) response to these items
and their current status follows.
Permanent Impoundments
Items 1 to 3 from the Divisions adequacy review letter:
The following impoundments are under consideration for Phase I Bond Release; Ponds 005, 006, 009, 015, 016,
017, and stock tanks; T -2, T -3, T -5, T -18, T -20, T -22, T -24, T -26 and T -27.
1.) In accordance with Rule 4.05.9(13), the Operator must submit a demonstration that an impoundment will be
left as a permanent feature. Appendix 20 -2.2 of the permit contains a number of these demonstrations for several
of the impoundments proposed to be left in place. The following impoundments are lacking the required
permanent impoundment demonstration: Pond 005, T -18, T -20, T -22 and T -24. Prior to the approval for any
bond release for these impoundments, Seneca Coal Company (SCC) must submit the required permanent pond
demonstration.
2.) Appendix 20 -2.1 of the permit contains letters signed by various landowners requesting permission for certain
structures /facilities to be left in place as a permanent feature. The following impoundments are lacking
permission of the landowner to be retained as a permanent feature: Pond 005, T -18, T -20, T -22 and T -24. Prior
to the approval for any bond release for these impoundments, SCC must submit documentation the landowner
desires for these structures to remain as a permanent feature.
3.) Attachment 20 -2 of the permit indicates SCC will submit documentation the Office of the State Engineer (SEO)
approves of the retention of each Sediment Pond and Stockpond. The following impoundments are lacking the
required SEO approval documentation: Sediment Ponds 005, 006, 009, 015, 016, 017 and Stock Ponds T -18, T-
20, T -22, T -24 and T -26 Prior to the approval for any bond release for these impoundments, SCC must submit
the required SEO approval documentation.
Response and Status: The response letter indicates the SEO is reviewing your request to leave these
impoundments as permanent features. The Division has not received the required documentation listed in
items 1 to 3 above. As these impoundments are a large portion of the land associated with this bond
release application, the Division recommends Seneca Coal Company request an extension of the decision
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines