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STATE Or COLORA00 nir,i mrnin InrR~ rl„„~.~,u„ III I11111111IIII III <br />999 <br />DEPARTMENT OF NATURAL RESOURCES <br />D. Monte Pascoe. Executive Director <br />MINED LAND RECLAMATION <br />423 Centennial Building, 1313 Sherman Street <br />Denver, Colorado 60203 Tel. (303) 666-3567 <br />David C. Shelton <br />Director <br />December 29, 1981 <br />TO: Dan Mathews <br />FROM: Jim Pendleton <br />RE: Review of th evis Bear Mine Permit Application <br />Pursuant to your request, I have reviewed the recently revised Bear Mine <br />Permanent Program Permit Application, submitted by Bear Coal Company. <br />I have reviewed this revised application to determine whether the applicant <br />has responded to my concerns as expressed in my memo to you dated April 29, <br />1981. I fozviard the following comments for your consideration. <br />~\ Refuse Disposal (2.05.8 and 2.05,9) <br />The applicant has amended pages 6C and 67 of the application to state that <br />underground development waste is deposited in an area designated as "spoils <br />pile" on Figure 2.05.4(2)(b)-Z(c). The applicant proposes "to cover the <br />existing spoils area with 6 inches of topsoil." <br />You expressed concern in the Preliminary Adequacy Review letter regarding the <br />pile's susceptibility to erosion, if the North Fork of the Gunnison's channel <br />were to meander towards the pile. The applicant has not responded to your <br />concern. <br />The application should demonstrate that the refuse in question is actually <br />underground development waste. Further, the application should address the <br />underground development waste "spoils pile" in conformance with the requirements <br />of Section 2.05.3(6)(a)(ii), demonstrating that the pile's design conforms <br />with the standards of Rule 4.09. This has not yet been accomplished by the <br />applicant. <br />Backfilling and Grading (2.05.9(2)(c)) <br />On amended page 70 of the amended application, the applicant addresses back- <br />filling and grading plans. In this discussion, the applicant refers to Volume <br />2 of the application, which is entitled "Slope Stability Analysis, West Portal <br />Area, Bear Mine" and was prepared by Rocky Mountain Geotechnical, Inc. However, <br />the report presents a selection of alternatives for backfilling and grading of <br />the portal area, two of which fulfill the requirements for slope stability within <br />Rule 4.19.2(1)(b). (See attached memo.) The preferred alternative presented <br />in that report is partial backfilling of the portal highwall, which would require <br />the approval of an appropriate request for variance from approximate original <br />contour, based upon steep slope mining conditions. In addition, this alternative <br />