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STATE OF COLORADO <br /> <br /> <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br /> <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br /> <br />September 4, 2013 <br />John W. Hickenlooper <br /> <br />Governor <br />Roy Karo <br /> <br />Mike King <br />Seneca Coal Company, LLC <br />Executive Director <br />P.O. Box 670 <br /> <br />Loretta Piñeda <br />Hayden, CO 81639 <br />Director <br /> <br /> <br />RE: Seneca II-W Mine; C-1982-057; Phase 2 Bond Release Application SL5 <br /> Adequacy Review No. 2 <br /> <br />Dear Mr. Karo; <br /> <br />The Colorado Division of Reclamation, Mining and Safety (Division) received the SL5 bond release application <br />from Seneca Coal Company (SCC) for a portion of the Seneca II-W Mine on May 15, 2013. The application was <br />deemed complete for review on July 18, 2013. The Division conducted the bond release inspection on August <br />thth <br />13 and 14, 2013. Please address the following items: <br /> <br />Bond Release Block: <br /> <br />1. One mesic drainage site encompassing a portion the 006 Gulch drainage is located within the SL5 bond <br />release area. This area is depicted on the Post Mine Vegetation Map; Exhibit 22-1. In accordance with <br />page 47 and 48 of Tab 22, revegetation success for cover in the reclaimed mesic portions of Dry Creek <br />will be evaluated by comparing the pre-mining baseline vegetation cover value for the Dry Creek mesic <br />drainage type to the cover in the revegetated areas along Dry Creek. It does not appear this data was <br />collected nor was this comparison completed. This area will need to be excluded from the SL-5 Bond <br />Release Area. Please submit a revised bond release map with this area removed from the bond release <br />area. <br /> <br />2. Land encompassing the following parcels; stock tanks T-24, T-20, T-18 and T-5 as well as post-mine <br />drainages PM 4-D and the upper reaches of PM 2-D are included in the SL5 bond release area and have <br />not been granted Phase I bond release. These areas must be excluded from the SL5 bond release area. <br />Please submit a revised bond release map with these areas removed from the bond release area. <br /> <br />3. Please determine the acreage of the exclusion areas discussed in items 1 and 2 above. <br /> <br />Revegetation Success: <br /> <br />4. SCC submitted an incorrect revegetation monitoring report for Attachment E. SCC submitted the correct <br />revegetation monitoring report on August 2, 2013. The Revegetation Success section of the SL5 bond <br />release application needs to be revised based on the correct revegetation monitoring report results and as a <br />result of SCC response to this adequacy review. <br /> <br />5. In regards to the weighted percentages for each vegetation type sampled in the extended reference area, <br />page 45; Tab 22 of the permit indicates; “As a block of reclaimed is delineated for bond release, then pre- <br />mining vegetation types will be evaluated to determine if these percentages need to be adjusted for that <br />particular block.” Using pre-mine vegetation data for the SL5 area, please demonstrate that the <br />percentages attributed to each vegetation type to calculate the weighted success standard are valid. If the <br />Office of Office of <br /> <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines <br />