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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />December 4, 2009 <br />Mr. Roy Karo <br />Seneca Coal Company <br />P.O. Box 670 <br />Hayden, CO 81639 <br />RE: Seneca II-W Mine (Permit C-1982-057) <br />SL-2 Phase I Bond Release Review <br />Dear Mr. Karo: <br />COLORADO <br />D IV IS I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />Harris D. Sherman <br />Executive Director <br />Ronald W. Cattany <br />Division Director <br />Natural Resource Trustee <br />As I discussed with you yesterday, based on our review of the SL-2 bond release application <br />and pertinent sections of the approved permit, there appear to be a number of deficiencies <br />associated with permanent road documentation needed for phase 1 bond release. Our <br />concerns focus on documentation for proposed permanent roads in the "original" permit area <br />mine block, because the South Extension mine block will be excluded from our proposed <br />approval decision. <br />Proposed permanent roads in the original permit block that were included within the SL-2 <br />release request area include Road "G", the Ridgeline Access Road, the Oil Well Access Road <br />portion of RCR 53C, a Section of Road "J", and all or portions of permanent light use roads LU- <br />1, LU-3, and LU-4. The permit contains necessary permanent retention documentation <br />including landowner letters and As Built drawings for Road "G", the Ridgeline Access Road, and <br />the Oil Well Access Road. Landowner request letters have been provided for the various light <br />use road segments listed, and for the segment of Road "J". However, As Built drawings <br />documenting conformance with applicable performance standards and permit specifications <br />have not been provided for these road segments. Permit Attachment 20-2 "Permanent <br />Structures Documentation" text includes commitments to provide As Built profile and cross- <br />sections for each of the permanent light use roads prior to Phase I bond release request. <br />Attachment 20-2 narrative indicates that, for Road "J", updated As Built documentation will be <br />provided following re-construction of a segment of the road impacted by a slide near the south <br />end of the road. We note that the slide affected segment of Road "J" is in the South Extension <br />Area and any associated reconstruction would presumably not affect the segment within the <br />original permit area. However, the current "J" Road As Built cross-sections reflect the <br />operational road width, and do not reflect reclamation modifications including the reduced travel <br />width (note that the same concern would apply to the As Built documentation for the proposed <br />permanent segment of "K" Road, in the South Extension area). <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines