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<br />STATE OF COLORADO Ril:nnRn U. I•A, rf,.v r~~o~ <br />DEPARTMENT OF NATUgAL RESOURCES <br />H aryls D. Sherman. Executive Director <br />11IINED LAND RECI~,AMA'TION <br />423 Centennial Builtling, 1313 Sherman Street <br />Denver, Colorado 80203 Tel. (303) 839-3567 <br />David C. Shelton <br />August 12, 1980 Director <br />T0: Pete livans ~ <br />PROM: .Jim Pendleton ~~~~- <br />SUEJECT: Permit Application Po The Orchard Valley D1ine, <br />Colorado We_tmorcl Inc. <br />III IIIIII III IIII III <br />999 <br />I have completed the review of the permit application and subsequent <br />submissions by Colorado Westmoreland, Inc. for the Orchard Valley <br />underground coal mine. I forward the following comments for your <br />consideration. <br />Problems lYhich Require ,amendment <br />(1) Request for variance from approximate original contour. <br />The application contains a technical presentation concerning the <br />relative slope stability of benches and portals backfilled to <br />approximate original contour versus benches and portals left in <br />their operational configuration. liowever, the application does not <br />address the question of the related slope stability of either <br />situation. <br />The permanent OSM and proposed Colorado regulations approach to <br />backfilling benches and portals to approximate original contour <br />does not address the relative stability of the backfilled versus <br />unbackEilled situation. Rather, those regulations allow variation <br />from backfilling to approximate original contour only if a minimum <br />static factor of safety of 1.3 cannot be achieved. The application <br />does not include a calculation of the static factor of safety for <br />either the backfilled or unbackEilled situation. The application <br />will have to be amended in order to include the calculation for <br />the backf.ill AOC situation. If the backfilled benches and portal <br />arc determined to be sub-standard in terms of slope stability, an <br />application for variance from AOC would then be appropriate. <br />(2) 1Vaste disposal pile stability. <br />The application contains no stability analysis or foundational <br />description for the proposed waste pile. The application 1ai11 have <br />to be amended to include the appropriate analysis. This analysis <br />should include treatment of topics such as; (1) a description of the <br />geology and hydrology of the proposed disposal area, (2) complete <br />physical and chemical analysis of the waste materials, (3) proposed <br />construction specificotions for the disposal bank, (4) descriptions <br />of any appropriate underdrain systems, (S) design configuration f.or <br /> <br />