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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />March 11, 2010 <br />Kathleen G. Welt <br />Mountain Coal Company, LLC <br />P.O. Box 591 <br />Somerset, CO 81434 <br />Re: West Elk Mine (Permit No. C-1980-007) <br />Technical Revision No. 120 (TR-120) <br />Refuse Pile Expansion East <br />Dear Ms. Welt: <br />COLORADO <br />DIVISION OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />James B. Martin <br />Executive Director <br />Additional adequacy review comments 16 through 22 are provided below. In addition to new comments, <br />the comments document Marcia Talvitie's previous comments of February 24, MCC's March 9th <br />responses to those comments, and her follow-up comments of March 10. <br />16. DRMS 24-Feb: Section 2.2.2 (Model Parameters) explains that Standard Penetration Tests <br />(SPTs) were conducted on in-place materials in the LRP. Data from the SPTs were analyzed to <br />establish the range of potential friction angle and undrained shear strength values to be <br />modeled. SPT and laboratory data for the LRP holes do not appear to have been provided with <br />Volume I OC. Please provide: a) a map showing the locations of the LRP borings in plan <br />view; and b) the boring logs, SPT values and laboratory results obtained for the LRP borings. <br />DRMS 10-Mar: a) In their March 9th response, MCC provided "Figure 1 - LRP Soil Boring <br />Locations". Please incorporate this map into the Figures of Volume IOC (suggestion: as <br />Figure 1-4). <br />DRMS 10-Mar: b) Boring Logs, SPT values and laboratory results for the LRP investigation <br />have been provided. Please incorporate the boring logs into Volume IOC -Appendix A. <br />Laboratory test results for the LRP were previously intermingled in Appendix B with results <br />from the RPE East investigation. Please organize the information presented in Appendix B <br />to make it easier to differentiate between the various investigations <br />17. DRMS 24-Feb: Figure 2-1 depicts friction angles of materials in the LRP plotted as a function <br />of depth. According to Section 2.2.2, the friction angles have been "determined from a blow <br />count correlation developed by Kulhawy and Mayne...". The friction angles so inferred range <br />from 26 to 58 degrees (or 62 degrees, as shown on Figure 2-2). Friction angles greater than 45 <br />degrees are unlikely, even in well-compacted sandy gravels. I reviewed the K and M study <br />(available on the internet), and observed nothing in that report that supports the extremely high <br />Office of Office of <br />Mined Land Reclamation Denver - Grand Junction - Durango Active and Inactive Mines