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s cEoalncE,nCsety Seneca Coal Company <br />October 31, 2005 <br />Mr, Mike Boutay <br />Division of Minerals and Geology <br />1313 Sherman St, Room 215 R <br />Denver, CO 80203 ECE~-~:~~D <br />(303) 866-3567 NOV 0 3 t£~3 <br />RE: Seneca II Mine Permit C-80-OS ~r~rsion ~f Minerals and Cealagy <br />TR-37 -Responses to Adequacy Review Comments <br />Dear Mr. Boulay, <br />Enclosed, please find three copies of revised and/or additional information Eor TR-37 addressing the Adequacy <br />Comments of your July 11, 20051etter. <br />A response to each comment is provided below and each comment is numbered accordingly. <br />1. The mmplwniz rrquirementr of St putative 32 have not been met. Rule 2.05.4(2) nquirzr a plan formodifying roadr to be <br />retained ar part oftheport-mining rand ure and mad modification must be in accordance with 4.03. Role 4.03.1 reguirer that all <br />haul roadr be removed and the land affected reclaimed unlerr retention of the mad it approved ar part of the past-mining land ure <br />and the mad complier with all applicable performance rtandardr. Approximately 8.9 miler of haul roadr are approved for <br />retention as permanent roadr, However, the typical permanent road crow-rections rubmitted with thin revirion application do not <br />provide ruffzcient derign information to determine compliance with perfonnamce rtandardr. <br />The current requirement on page 13-SS of the PAP stater that permanent road will be narrowed to 20 feet wide forpart-mining <br />use. Some wider arear may be needed for loading/unlaadr'ng. If thir zr the care then there arear should be indicated and <br />inrorpord into the permanent road derignr. <br />Narrowing of the roadr it a prudentplan, conrirtent with the approvedport-mine land rue. Reduction of the roads will enrure long- <br />term drainage stability, educe erorion and maintenance requiremenU, and will enhance the likelihood of ruccer, ful bond mleare. <br />The proposed plan rubmitted with this revision application dver not meet theregeneralgoals and includer road widths ranging xp to <br />45 feet. Bared on recent inrpectianr, it appearr that certain sections of the propored permanent roadr exceed the typical emsr-rectzon <br />widthsgiven. <br />As previously inquired by Stipulation 32 please provide cert~ed derigns for the propared permanent roadr coarirtent with the <br />currentpermit requirement to reduce road widths to 20 feet, and demonrtrating compliance with applicable performance rtandardr to <br />include: vertical alignment, cut nape and embankment information demonstrated on appropriate crow-radians and profiler. Pleare <br />update the permit text accardin~. Pleare afro revise Exhibit 13-2 to remove Raad E 1 from the Backfill and Grading Schedule <br />far2005. It would adro be helpful to n-derignate the madr toted under she Backfrll and Grading Schedule an Exhibit 131A ar <br />`Raadr to be Narrowed"and provide a rShedule for completing the work. There war no schedule listed for these roads under the <br />Backfzll and Grading Schedules &rted at the bottom of Exhibit 13-2A. <br />• <br />Seneca Coal Company • P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 2763707 • FAX (970) 276-3014 <br />