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<br />I ~ <br /> <br />2 <br />The recommendations contained in CTL Thompson's May 5, 1995 report to Colowyo could <br />be incorporated into this revision. The remedial measures should ideally be approved in <br />the permit prior to implementation. However removal of the topsoil stockpile and <br />excavation of the spring sources should proceed as soon as ground conditions allow. <br />The movement expressed on the slope next to the West Pit excess spoil fill has now <br />extended to the edge of, and possibly into, the fill. The stability of the fill is not being <br />incorporated into NOV C-90.005. However, we are concerned that the assumptions used <br />in the stability analysis of the fill and the monitoring plans for verifying the fill's stability <br />may not be appropriate under present circumstances. We are not aware that the water <br />source next to the toe of the fill or the water presently impounded in the pit were <br />anticipated when the CTL Thompson design work was performed. In order to verify the <br />stability of the excess spoil £II, we will also require that Colowyo, <br />1. visually monitor the face of the fill for any evidence of instability on a weekly <br />basis, at least until topsoil is spread over the fill, <br />2. submit an appropriate analysis and account of the infiltration of water <br />presently impounded in the West Pit, specifically addressing whether the water may <br />be infiltrating into the excess spoil fill, <br />3. install the piezometer included in the fill construction plans as soon ground <br />conditions allow. If water is encountered in the fill, a second piezometer on an <br />upper bench of the fill should be installed so the phreatic surface within the fill can <br />be estimated. <br />4. explain how and if the recommendations to line pit benches and seal coal <br />seams on the north end of the pit are being implemented. These recommendations <br />are found on page 13 of the CTL Thompson report in Exhibit 19, Section I.c of the <br />permit application package. <br />