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James C. Stevens <br /> Senior Reclamation Specialist <br /> Mined Land Reclamation Division <br /> 215 Centennial Bldg. <br /> 1313 Sherman St. <br /> Denver, CO 80203-2273 <br /> Dear Mr. Stevens: <br /> RE: Tunnel Waste Disposal Pile <br /> Mid-Continent would like to comment on issues relating to the rock tunnel pile <br /> concerning drainage on the south side of the pile, and requirements for construction of <br /> a compacted 2:1 slope. <br /> The thrust of our comments is that a distinction must be made between final and <br /> temporary slopes; that the requirements of the regulations and the permit itself relate to <br /> final slopes. The area to the south of the pile is one of ongoing and anticipated disposal <br /> activity, so that the slopes are temporary. <br /> Mid-Continent notes in the approved permit application, concerning the Rock Spoil <br /> Disposal Area, Chapter II, Operations Description, that the estimated volume of the pile <br /> is approximately 365,000 cu. yds. of material, whereas the estimated capacity of the pile <br /> is 1.08 million cu. yds. <br /> Further additions to the pile are anticipated. <br /> Regulations <br /> The applicable regulations: <br /> 4.09 DISPOSAL OF EXCESS SPOIL AND UNDERGROUND DEVELOPMENT WASTE <br /> 4.09.1 (7) The spoil or waste shall be hauled or conveyed and placed in horizontal <br /> lifts in a controlled manner, concurrently compacted as necessary to ensure mass <br /> stability and prevent mass movement, covered, and graded to allow surface and <br /> subsurface drainage to be compatible with the natural surroundings and ensure a <br /> long-term static safety factor of 1.5. <br /> (8) The final configuration of the fill shall be suitable for postmining land uses <br /> approved in accordance with 4.16, except that no depressions or impoundments <br /> shal be allowed on the completed fill. <br />