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Edna 4/93 page 5 <br />P&M has elected to use check dams as part of the West Ridge hydrologic <br />reconstn:rtion plan. These check dams are being placed in drainages where <br />erosion has been a problem in the past. I believe it was stated that eleven had <br />been constructed so far. The design for these check dams includes across- <br />section of the structures. The cross-section shows an earthen embankment as a <br />core with ten inches of rock over the top. P&M had proposed this concept about <br />two or three years ago on it's Indian lands mine, the McKinley Mine. Initially OSM <br />agreed with the concept, then Western Support Center and Albuquerque Field <br />Office (AFO) representatives reviewed the proposal and decided that the structures <br />would also have to meet the Federal impoundment regulations. The structures are <br />designed to impound water rather than be porous. P&M was made aware of <br />OSMs decision and elected not to construct the check dams. I am not issuing a <br />TDN on this condition since the structures were snow-covered and I could not tell if <br />water was being impounded. AFO will continue to review this situation during the <br />regular oversight process. <br />P&M questioned their liability if they reclaimed the landfill for Routt county. We <br />could not give them a complete answer, but stressed that P&M should proceed <br />very carefully on this. One of the ideas stated was that the road would be <br />relocated to the edge of the hill and over the reclaimed landfill. Since this is a <br />permitted road, P&M would have to permit this new location. I do not know what <br />the implications would be of permitting an area that was once a landfill if problems <br />such as ground water contamination, etc., occur from this area. <br />