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March 21, 2014 C- 1996 -083 /Bowie No. 2 Mine SLB <br />• Several trucks, excavators, bulldozers and compactors were working the refuse material. <br />• The designated drying area was idle; material placed through the fall and winter remained uncompacted, as <br />currently approved. <br />The coverfill pile at Gob Pile 43 has greatly diminished in volume since the last inspection. A comparison of <br />the coverfill pile in the December 18, 2014 DRMS aerial photos to the March 21, 2014 photos indicates that a <br />large amount of cover fill material has been removed from the stockpile. No regraded refuse has been <br />covered with coverfill material at any of the gob piles since Fall 2013, when the upper portion of Gob Pile 44 <br />was covered with stockpiled material from Gob Pile 42. The material removed from the stockpile has instead <br />been mixed into Gob Pile 43 to attain the proper moisture levels for compaction. The reduction in stockpiled <br />material raises concerns for the Division, primarily: <br />• The amount of material available for cover placement appears to be less than what is necessary for <br />reclamation at this point in time. <br />• The stability analysis provided for approval of Gob Pile 43 is based on the assumption that the disposal <br />area will be constructed with coal refuse material, and may not be valid when coverfill material is added to <br />assist with drying and compaction efforts. <br />The Division is currently reviewing revised stability analyses with Technical Revision No. 84 for Gob Pile 43 and <br />Technical Revision No. 85 for Gob Pile 42, and will ensure that the appropriate assumptions are used to evaluate <br />the stability of Gob Pile 43. <br />The material balance, however, will need to be addressed immediately. Based on Division observations and a <br />review of the materials submitted in BRL's response to the Division's adequacy concerns with Technical Revision <br />No. 77, there does not appear to be sufficient cover material available for reclamation of the gob pile areas. <br />At Gob Pile 42 there are currently approximately 36.5 acres of refuse that would require cover. At the proposed <br />cover placement depth of 3.5', 206,103 cy of material would be required. There are approximately 16 acres of <br />refuse requiring cover at Gob Pile #3. At a replacement depth of 3', 77,740 cy of material would be required. At <br />Gob Pile 42, there is approximately 143,219 cy of stockpiled material available, and 43,064 cy at Gob Pile 0. <br />The total required material at this point is approximately 283,843 cy. It appears that BRL has stockpiled 186,283 <br />cy, but that volume is estimated and has not been verified by survey. It is also not clear when the estimate of <br />available material at Gob Pile #3 was completed, and at the current rate of consumption, there may well be <br />considerably less stockpiled than was estimated. <br />BRL must conduct an accurate survey of the volume of stockpiled coverfill material, to determine the <br />amount of material currently stockpiled for Gob Piles #2, #3, and #4. The survey must be conducted and <br />the results provided to the Division no later than April 30, 2014. The survey data will be used to determine <br />whether BRL is in compliance with: <br />• Rule 4.10.1(5) requiring a minimum of 4' of cover material to be placed following final grading of refuse <br />material. Specifically, whether the requirements of the rule could be met with currently available coverfill <br />material, <br />Number of Partial Inspection this Fiscal Year: 13 <br />Number of Complete Inspections this Fiscal Year: 3 <br />Page 3 of 7 <br />