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:, <br />Mountain Coal Company <br />West Elk Mine <br />Post Office Box 597 <br />Somerset, Colorado 81434 <br />Telephone 970.929-5075 <br />December 1, 1997 <br />Mr. Michael Boulay <br />Colorado Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver. CO 80203 <br />iii iuiiiiiiiiii iii <br />999 <br />n_~.cl : ~7 <br />DEC ~ 4 1997 " <br />UiaoiUn Or MinCrnW !l UCOIUyy <br />RE: Subsoil Pile on Lower Refuse Pile; West Elk Mine; Permit No. C-80-007 <br />Dear Mike: <br />This letter is provided in response to the Division's request from the inspection report <br />dated August 26, 1997, regazding an inspection which occurred on August 19, 1997, <br />to substantiate that the removal of the subsoil from the pile on top of the Lower <br />Refuse Pile to the road below the RCC buttress is a practice that is consistent with <br />and covered by current permit provisions. Mountain Coal Company (MCC) assumes <br />that the Division has asked this question in regazds to the reclamation of the Lower <br />Refuse Pile (I,RP) to ensure adequate subsoil is available for reclamation of the LRP. <br />As explained to you during the inspection, and as evident in the permit and permitting <br />history, this subsoil pile is extra subsoil not required for reclamation of the LRP. The <br />subsoil that was on the top of the LRP was relocated from the east facing bench of <br />the LRP, as approved in Technical Revision No. 78. The subsoil that had been placed <br />on the east bench came from numerous construction projects on the West Elk Mine <br />site. Subsoil from the east bench was used as a lay-down area for the relocation of <br />the topsoil pile (also approved in TR#78) and in berms around the topsoil pile. <br />Approximately 1,000 CY of subsoil was placed in the pile on top of the LRP. <br />Minor Revision No. 191 added approximately 2,500 CY of subsoil to this pile, to <br />bring the total volume of the pile to 3,500 CY. This volume was later updated with <br />an as-built volume of 3,800 CY (Minor Revision No. 204). The added subsoil was <br />generated from the preparation of the Materials Storage Bench (MSB) for concrete <br />surfacing. <br />These additional volumes added to the subsoil pile on the LRP were included in the <br />update of the pile volume on Figure 2.OG, in Exhibit 51 which depicts the current <br />LRP configuration (as of December 1996). These volumes of subsoil had never been <br />added to Table 36, Approximate Topsoil Stockpile Volumes for West Elk Mine Site. <br />Table 36 reflects the amount of topsoil and subsoil available for reclamation of the <br />