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ST41E X11' (; Ol ~R4OG Ni(; H:.N I1 U. IPMM, Gnv crn (v III'll lll'll "II'll 999 DEPARTMENT OF NATURAL RESOURCES , D. Monte Pascoe, Execu live Director MINED LAND RECLAMATION 423 Centennial Building, 13T35herman Street Denver, Colorado 80203 Tel. (303) 839-3567 David C. Shelton Director June 19, 1981 TO: Fred Banta and Brian u on FROM: Jim Pendleton SUBJECT: Review of the eotech 'cal Aspects of the Meeker Area Mines Permit Aonli Pursuant to your request I have reviewed the extensive documentation of Northern Coal Company's permanent program permit application for the Meeker Area mine complex. I forward the following comments for your consideration. Refuse Disposal The application states that section 13 of Chapter C is identical to the material submitted to the Division on June 13, 1980. It is not, however, a copy of the entire approval process documentation involved in the approval of phase I of Northern's waste disposal pile. For completeness the application should include the series of exchanges in letter form which transpired prior to approval of phase I. The application characterizes the material as possibly constituting "durable rock". sacking discrete materials data at the time of phase I approval, the Division required that the design of the waste pile reflect nondurable waste material. My personal observation of waste material in place at the phase I site verifies the nondurable nature of Northern's waste material. If the applicant, subsequent to approval of phase Z, has completed additional analyses of the materials durability the test results should be included within the application documents. Perhaps the application would be simplified by the deletion of the optional "durable" design material placement specifications. Page 13-4 incorrectly states that the water table is deeper than 5 feet through- out the waste pile site, which contradicts the water depth data shown in table 13.2.2. This discrepancy was clarified in the Division/applicant letter exchanges during the approval process for phase I which should now be added to the application. This problem was later mitigated by the installation of an interceptor drain system near the toe area of phase Z. Documentation of this installation should also appear within the permit application and included exhibits. The application states that approval is only requested for phase I of the disposal pile. is the applicant now interested in pursuing approval of the entire disposal pile? If so, the application should be appropriately amended.