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~ Twentymile Coal Company July 14, 1994 Kent Gorham Environmental Protection Specialist Division of Minerals and Geology Office of Mined Land Reclamation 1313 Sherman Street, Room 215 Denver,COlorado 80203 RE: Refuse Pile Construction Permit No. C-82-056 Dear Mr. Gorham: ~e~~ III III III III I'll III sss 29515 Routt County Roatl ><27 Oak Creek, CO 80467 Phone (303) 879-3800 nr/''CI~/FQ JUL 151994 .. .. _.,.,~~~G~a~~..uso;c9Y Per our recent discussion Twentymile is requesting to delay the construction of the refuse pile. The construction delay will provide Twentymile additional time to research if it is possible to put the refuse material underground. Also, the site of the refuse pile, if it is to be constructed above ground, will be greatly decreased due to the addition of a preparation plant next year. The projected yardage will be decreased from 20,000,000 yards to 400,000 yards. This decrease results in a much smaller site on which the refuse pile would be constructed. In reference to the underground storage of the refuse material an initial contact has been made with MSHA. From their perspective it appears placing the refuse underground is very desirable; however, I am still researching if this will be possible. The other issue associates with underground placement of the refuse centers around receiving approval in a timely fashion. Twentymile is pursuing this option, but it is doing so with guarded optimism. The redesign of the refuse pile will take additional time. Twentymile will pursue the construction of a side hill pile as opposed to one that will go across the valley. In order to determine if this is feasible it may require CTL/Thompson to visit the site to determine the best location for the refuse pile. It will stay in the same general location but will not extend across the valley. Mark Gray who did the original design work is on vacation and I will be talking with him next week about a site visit. In any event the refuse pile design will change along with the necessary diversion structures. I anticipate a technical revision will be submitted during early fall to address the new design.