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eivhulcl? <br />c <br />oCompany Seneca Coal Corn an <br />? P Y <br />September 28, 2009 <br />Mr. Daniel Mathews <br />Division of Reclamation, Mining and Safety <br />101 South 3?, Suite 301 <br />Grand Junction, CO 81501 <br />(970) 242-5025 <br />RE: Seneca II-W Mine (Permit C-1982-057) <br />Technical Revision (TR-65) - Revegetation Monitoring <br />Response to Adequacy Comments <br />Mr. Mathews, <br />?a-- ' <br />5EP ? p?pp9 <br />pv?sw" u? aid Sa?e?1 <br />?1?ri?n9 <br />Seneca Coal Company (SCC) reviewed your letter dated August 24, 2009 and has prepared the following <br />responses. <br />1. The items listed under `Annual Reporting"on amendedpage 40 were revised to delete references to light use road <br />updates and submittal of regarded topography documentation and comparison with approved topography. <br />0 Please provide explanation/just cation for these proposed deletions. <br />Response: It appears that this information doesn't belong in the Annual Reclamation Report since the <br />information is included in the approved PAP under permanent roads and in the Phase I bond release <br />application when appropriate. Additionally, this information is not included in the Annual Reporting <br />description in the other two (2) Seneca Mines PAPs. Therefore, SCC has deleted the reference from Tab 22. <br />2. The section titled `jgnoling Intensig'' at the top of amended page 43appears to be relict from the interim monitoring <br />narrative of the current approved permit. Inclusion of this as a sub-heading under "Testing for Successful Reclamation" <br />would not appear to be appropriate and would likely lead to confu ion. Sampling intensity for success demonstration <br />must be `statistically valid" in accordance with Rule 4.15. 11 requirements Note that the next to last sentence of the <br />section states that ..the monitoring data are intended for evaluation.... and not for strict statistical analysiswhich is <br />not appropriate in the context of success demonstration for bond release. <br />Please delete the section or revise as warranted to address sampling intensity for statistically <br />valid demonstrations ofreveget3tron success. <br />Response: The section titled "Sampling Intensity" has been revised. <br />3. At the bottom of amendedpage 45 under `Lxtended Reference Area Abbroach " the final sentence of the currently <br />approved text (As a block of reclaimed land is delineated...) was deleted <br />• <br />Seneca Coal Company . P.O. Box 670 • Hayden, Colorado 81639 <br />Telephone (970) 276-5217 . FAX (970) 276-5222