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iii iiiiiiiiiiiiiiii <br />999 <br />STATE OF COLORADO <br />DIVISION OE MINERALS AND GEOLOGY <br />Department of Natural Resources <br />I J 13 Sherman 51., Roont 215 <br />Denver, Colorado 80203 <br />Phone: (3031 R66-3567 <br />FAX: U031 832-8106 <br />DATE: January 10, 1997 <br />TO: Mike Boulay <br />FROM: Jim Pendleton <br />~~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />lames 5. Lnchhead <br />Evecmive Director <br />Michael B. Long <br />Division Director <br />RE: Mountain C al Co any - TR-78 - Supplemental <br />Lower Refuse ile - Stability Addendum #2 <br />(Permit No: C-80-007) <br />In response to my third set of adequacy comments, dated November 1, <br />1996, Mountain Coal Company (MCC) commissioned Harding Lawson <br />Associates (HLA) to revise their amended stability analysis of the <br />West Elk mine's Lower Refuse Pile reconfiguration. Their second <br />revised analysis applied an amended perched water table assumption <br />to their earlier configuration. The soil material strength <br />parameters and distributions were unchanged, with the amendment of <br />the perched saturated zone. In completing this analysis, HLA used <br />the U.S. Army Corps of Engineers "Hydrologic Evaluation of Landfill <br />Performance (HELP) analytical software to model the perched water <br />table development within the pile. HELP was developed by the Corps <br />for the EPA and is considered the definitive analytical software <br />for such perched water table predictive modeling. <br />The modeled perched water table configurations appear to have been <br />appropriately completed. As in the earlier analysis, three <br />critical cross sections were analyzed. As in the earlier analysis <br />the waste material was modeled using the worst case assumption, <br />that of the 10°s fines material. Profile 3 (the east facing slope) <br />was determined under the projected perched water table <br />configuration to have a static slope safety factor of 1.65. <br />The second supplemental submittal has satisfied my earlier concerns <br />regarding stability of the Lower Refuse Pile at the West Elk Coal <br />Mine. MCC may continue to place refuse on the remaining portions <br />of the LRP in accordance with the proposed configuration. <br />cc: David Berry <br />Susan McCannon <br />doe: M:\COAL\JAP\MCCLRP3.SAN <br />JP/jP <br />