REV07623

• Permit No: C1980006
• IBM Index Class Name: Revision
• Doc Date: 11/10/1997
• Doc Name: MARR TR-17
• From: DMG
• To: JIM BURNELL
• Type & Sequence: TR17
• Media Type: D
• Archive: No

III IIIIIIIIIIIIIIII~
STATE OF COLviv-~9vv
DIVISION OF MINERALS AND GEOLOGY
Depanmenl of Natural Resuurces
1717 Sherman St., Room 215
Denver, Colorado 80203
Phone: (303) 8fi6~3567
FAX: [phone]
Date: November 10, ] 997
To: Jim Burnell
MEMORANDUM
From: Harry Ranney ~~
Re: MarrTR-17
DEPARTMENT OF
NATURAL
RESOURCES
Roy Romer
Governor
~ame~ S. Lochhead
E~ecunve Director
Michael B. Long
Division Director
I have reviewed TR-17 and have the following comments concerning the proposed changes to
the permit:
[ have doubts as to the estimated 3,000 cubic yards of coal waste that needs to be buried
at the new location. The tipple area is approximately 8 acres in size and the estimated
waste equates to about 2.8 inches of material throughout the site. I did not see in the
revision any data as to how they obtained this estimate, however, from past experiences at
other tipple sites, I believe this estimate to be far short of the volume of waste.
2 Regardless of the amount of waste to be hauled and buried, Kerr only proposes that 1200-
1800 cubic yards of material be hauled back for fill. This represents approximately 1.2 to
1.7 inches of fill replacement over the 8 acre site. Since the site is barely above the water
table, I recommend that a one for one removal and replacement strategy be used to insure
problems at the tipple site might be minimized.
The material used as the replacement fill needs to be sampled for suitability as a growth
medium, as well as to deternrine if any supplemental fertilization will be necessary [o
sustain plant growth.
4. The requirement of growing plants to stabilize erosion may be moot if further details of
the end use of the site were more fully described and all approved county permits
available for our review.