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A9s. Snndra L. Brown <br />© Colorado Division ojMinerals fi Geology <br />Deremher 13, 7998 <br />Page ? <br />The noted facilities are primarily pre-fabricated steel frames and shells and/or equipment <br />(crusher and conveyors). As indicated, the equipment is probably salvageable and would be <br />sold and moved off-site by the buyer. Eliminating the Shop/Utility Building and given that <br />all of the noted volumes are contained volumes and salvage considerations, the actual <br />volume of steel demolition debris to be disposed of is conservatively estimated at 10 percent <br />of the total contained volume or 350 cubic yards. This figure has been incremented to 500 <br />cubic yards to provide a reasonable margin for any errors in the volume estimate. <br />3J Kerr is proposing to bury approximately 3,000 yd' of coal with the demolition debris. How <br />was this volume estimated? The tipple area is approximately 8 acres in size, so the estimated <br />waste equates to 2.8 inches of material across the site, plus there is a small stockpile. <br />Recognizing that the entire <ite is not covered with coal fines, this estimate appears to be less <br />than the actual volzrme of coal present. Please explain how the estimate of coal volsrnze was <br />Aktde. <br />Response: George Patterson, former Mine Manager for Kerr Coal Company, provided the <br />Figure for coal fines volume. In order co address the DMG comment, Mr. Patterson was <br />contacted re: the basis for this estimate. Following removal of the remaining stockpiled coal <br />from the tipple area, Mr. Patterson dug a number of shallow holes in those areas where <br />coally material was evident on the surface to determine the average thickness of coal fines a[ <br />each hole location. Using these average thicknesses and paced distances, Mr. Patterson <br />calculated the volume of coal Fines remaining in the tipple area. He also indicated that what <br />appears to be a small pile of remaining coal fines is, in fact, a shallow layer of coally materiail <br />over a small gravel pile. Based on site specific information and resulting calculations, the <br />3,000 cubic yard figure appears to be accurate. <br />3J Rule 4.11.4 requires that fere prevention meas:sres be discussed. P/ease address this <br />requirement. <br />Response: None of the materials that Kerr is proposing to dispwe of, including coal fines <br />and steel and concrete demolition debris, represent a fire hazard. The coal fines have been <br />exposed to oxidation and weathering for a number of years with no problems co dale <br />relative to spontaneous combustion. This is probably due to the low potential for this coal <br />co spontaneously combust coupled with the fact that the coal fines are mixed with surficial <br />soil materials, further limiting the potential for combustion. Kerr proposes to remove and <br />bury these materials under a soil cover, which will further reduce the potential for <br />spontaneous combustion and fires. <br />4J Map 37A, Post>nining Topography, submitted with the TR application labels the entire <br />shop/warehouse facility pad as the solid waste disposal site. The text refers to an area south <br />and east of the shop/warehouse pad which is also shown on the map. Please provide details on <br />the areal size and depth of the disposal area and clearly designate the waste disposal area on the <br />map. <br />Response: The entire shop/warehouse pad area was previously identified and has been <br />approoed as a disposal site for demolition debris from the shop/warehouse facilities. A large <br />area was identified [o provide Kerr with the flexibility necessary to select the best location <br />v- ~3,nra.,e~aep,mv ~n <br />,a: ,ns n~ <br />