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<br />Mountain Coal Company <br />Weal Elk Mine <br />Post Office Box 591 <br />Somerset, Colorado 81434 <br />Teleplane 303 95015 <br />Fax 303949-5695 <br />August 25, 1994 <br />Ms. Christine E. Johnston <br />DIVISION OF MINERALS AND GEOLOGY <br />Office of Mined Land Reclamation <br />] 313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />R>`C~IVEp` <br />III llll«Illll«!11 <br />AUK 29 <br />Ca`sron o; nure;als a 4nalo`'S' <br />Re: West Elk Mine, Permit No. C-80-007, Brush Disposal Alternatives <br />Dear Christine: <br />After receiving contractors' cost estimates ranging from about $50,000.00 to $110,000.00 for the <br />disposal of brush from the Materials Storage Bench area at the Delta County landfill, Mountain <br />Coal Company (MCC) began considering other alternatives for brush disposal. Included in this <br />consideration were using achipper/shredder to break the oakbrush into small pieces for mulch or <br />incorporation in the topsoil stockpile, stockpiling the brush nearby for later burning or for <br />redistribution on the seeded topsoil stockpile (for small game cover and/or seedling shade), or <br />"brush-crushing" the entire area first, breaking the material with the bulldozer tracks, and <br />incorporating the vegetative debris in the topsoil stockpile. Unbroken stems greater than about <br />three inches in diameter would be stored nearby and later scattered on the seeded topsoil <br />stockpile. <br />We understand that the Delta County landfill has less than two years of projected life remaining <br />and is only accepting limited amounts of vegetative wastes. Considering this, it is unlikely that <br />they will accept the amount of unconsolidated blush that will be removed from the construction <br />site (thus, the high disposal costs). Oakbrush wood is dense and would be dirt-covered after <br />removal from the site, making it undesirable for chipping, as the blades of a commercial <br />chipper/shredder would be quickly dulled or ruined. Burning. is a viable option, but with the <br />current burning ban, may not be completed for some time. <br />MCC believes that the only feasible alternatives are to temporarily stockpile the brush for later <br />redistribution over the seeded topsoil stockpile or to brush-crush the area first, redistributing only <br />the unbroken, lazger diameter stems over the seeded topsoil stockpile <br />° D <br />