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REP37849
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REP37849
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Entry Properties
Last modified
8/25/2016 12:17:15 AM
Creation date
11/27/2007 7:54:18 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1983058
IBM Index Class Name
Report
Doc Date
6/25/1990
Doc Name
TWIN PINS TR-03 SUPPLEMENTAL SUBMITTAL-COAL WASTE PILE PN C-83-058
From
MLRD
To
LARRY ROUTEN
Permit Index Doc Type
Waste Pile/Fill Report
Media Type
D
Archive
No
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-~ ' <br />~ III IIIIIIIIIIIIIIII <br /> 999 <br />STATE OF COLORADO <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, CO 60203 <br />303 866.3567 <br />Fax: 303 832-6106 <br />DATE: June 25, 1990 <br />pF. ~~[~ <br />~~ <br />Y+~~ <br />'revs ` <br />Rq Romer, <br />Governor <br />Fretl R. Banta, <br />Diwsion Deettor <br />T0: Larry Routen <br />FROM: Jim Pendleton ~~~~ <br />RE: Twin Pi TR-0 upplemental Submittal - Coal Waste Pile <br />(Permit No: C-83-058) <br />I have review the supplemental submittals made by the applicant in response to <br />my earlier adequacy commehts. The operator has responded adequately to the <br />majority of the comments included in my adequacy memo dated May 3, 1990. <br />(1) I expressed a concern about potential subsidence of the waste pile due to <br />underground workings beneath the site. Rule 2.05.3{8)(a)(i)(D) requires <br />a discussion of potential subsidence impact, if any is believed to <br />exist. The applicant has included a mine map of the area of the proposed <br />pile which documents that the immediate location of the pile has not been <br />undermined. My concern is resolved. <br />(2) In response to ~ concern, the applicant has amended the TR-03 <br />application (Paragraph 1, page 4) to state that the pile will be <br />inspected quarterly, as required by Rule 4.10.2(2)(a1. <br />(3) In response to my observation that an underdrain is required beneath a <br />coal waste bank, the applicant presents a rationale for an underdrain <br />being unnecessary. While I do not necessarily disagree with the <br />applicant's opinion, Rule 4.10.3(1), adopted as required to be "as <br />effective as" the equivalent OSMRE regulation, does not allow exemption <br />from underdrain installation, It does, however, state that "a proper]y <br />designed subdrainage system shall be provided..." The significant <br />consequences of constructing a pile without a subdrain system and <br />discovering after the fact that one was needed, resulted in the exclusion <br />of exemption from subdrain construction. In this instance, I believe a <br />very simplistic french drain (shallow trench filled with cobbles and <br />covered with filter fabric daylighting outside the fill footprint) would <br />comprise a "properly designed subdrainage system", in compliance with <br />Rule 4,10.3(1). It is not within the discretion of the Division to <br />approve construction of a coal waste pile without a subdrain system. <br />(4) In response to nU' comment requiring a demonstration of a static slope <br />safety factor in excess of 1.5 (Rule 4,10.4(2)), the applicant has <br />submitted a slope stability analysis prepared by Lincoln Devore, lnc., <br />consultant to the applicant. This analysis, prepared in accordance with <br />the pruoent state of the art, including appropriate material strength <br />
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