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SL -4 Adequacy Review 2 <br />Page 2 <br />documentation. <br />Response and Status: The response letter indicates the SEO is reviewing your request to leave <br />these impoundments as permanent features. The Division has not received the required <br />documentation listed in items 1 to 3 above. As these impoundments are a large portion of the <br />land associated with this bond release application, the Division recommends Seneca Coal <br />Company request an extension of the decision date for the SL4 bond release application to <br />allow additional time to obtain the necessary documentation discussed above. Or, SCC could <br />withdraw these parcels from the phase I bond release request. In response to items 1, 2, and 3 <br />documentation and requested approvals are in the hands of the SEO. Once approvals are <br />received, SCC will complete the permanent pond requests and documentation. <br />Response: SCC has requested and received an extension of the decision date until September 3, 2013 in <br />order to compile and submit the required information. <br />9.4 Acre Pit Ramp Slide Area <br />4) Attachment 20 -E of Tab 20 contains a remediation plan for the pit ramp slide, during MR 72, SCC <br />expanded the remediation activities for the pit ramp slide. The expanded plan is included in a <br />letter from the North West Colorado Consultants dated October 1, 2012 and is included in the <br />above referenced attachment. It appears two surface drains have been constructed in a V <br />configuration and range from 2 to 3 feet in depth and are lined with Turf Reinforcement Material <br />(TRM). The Division has observed these surface drains during site inspections. <br />Also, the expanded plan calls for one and possibly two subsurface trench drains to be installed. <br />These trench drains are further discussed in the Divisions June 25, 2012 inspection report and <br />originally in the August 31, 2011 Landslide Repairs at Seneca II -W memorandum from Jill <br />Carlson with the Colorado Geological Survey included in Attachment 20 -E. It does not appear <br />documentation has been submitted to the Division that the trench underdrains have been installed. <br />Based on the Division's August 28, 2012 inspection report, it appears these underdrains may not <br />have been installed. The Division believes these underdrains are necessary for the long term <br />stability of the pit ramp slide area. SCC will need to submit documentation such as as -built <br />designs and plans to substantiate these underdrains have been constructed. If the underdrains <br />have not been constructed, the Division will not approve Phase I bond release for the 9.4 acre <br />area encompassing the pit ramp slide. <br />Response and Status: SCC's response letter included a request for the Division to retain the <br />9.4 acre parcel surrounding the Pit Ramp Slide in the SL4 bond release area. Included with <br />this request was a letter from North West Colorado Consultants, Inc (NWCC) with <br />justification to not install the under drain system. The Division's engineering staff reviewed <br />this request and concurs with NWCC's recommendations. Based on this finding, the Division <br />will retain this parcel in the bond release area. Please submit a minor revision to update the <br />remediation plan for the Pit Ramp Slide area. <br />Response: Minor revision (MR -75) accompanies this response letter. <br />