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<br />United States Department of the Interior <br />OF'FlCE OF SURFACE MINING <br />RECLAMl:1'ION AND ENFORCEMENT <br />BROOKS TOWERS <br />1020 15"I'H STREET <br />DEN V ER. COLORA DO 80202 <br />November 21, 1991 <br />iii iuiiiiiiiiu iii <br />999 <br />r <br />~o <br />-~ ~ <br />1 A~~~~ V L® <br />NOV 2 6 1991 <br />MEMORANDUM <br />TO: Files <br />Mined Land <br />Reclamation Division <br />FROM: Assistant Director <br />Western Support Center <br />SUBJECT: Meeting November 19, 1991 with Representatives of <br />Col"owyo Coal Company, Colorado MLRD, and OSM's Western <br />Support Center and Albuquerque Field Office as Listed <br />on the Attached Attendance Sheet <br />The meeting commenced about 10:00 a.m. for an hour and a half to <br />discuss and determine the appropriate Colorado State Program <br />rules for permitting two excess spoil valley fills proposed for <br />the Colowyo mine. The fills, identified as the West pit and <br />Section 16 excess spoil fills, are described in Exhibit 19 of a <br />May 1991 application for permit renewal and permit revision. <br />A short discussion occurred about the applicability of the <br />alternative design specifications in rule 4.09.1(3), General <br />Requirements. OSM explained its position, which has been <br />consistent over the years, that the specific design requirements <br />of rule 4.09.2, Valley Fills, have precedence. Therefore, the <br />alternative specifications provision is not appropriate for <br />permitting the proposed valley fills. <br />Discussion then turned to the ability of the excess spoil fill <br />design to meet the specific requirements of rule 4.09.2, Valley <br />Fills. The design and stability analysis submitted with the <br />permit application materials shows a long-term static safety <br />factor of 1.5 or greater for the fills [Rule 4.09.2(1)]. It was <br />agreed that this conclusion, if confirmed by Colorado MLRD <br />review, is key to the technical demonstration of compliance with <br />the valley fill rules. The following specific points relative to <br />this proposal were discussed and decided: <br />• Excess spoil that is end dumped to form horizontal <br />lifts of from 50 to 100 feet high could constitute <br />placing excess spoil "in a controlled manner." [Rule <br />4.09.2(3)] <br />