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Carl 8 Mount, 6175 W Ohio Ave, Lakewood, CO 80226 <br />Second, obtain a full elemental characterization of the waste material to include geochemistry and <br />mineralogical data in order to help determine static levels of waste solubility. Organic constituents most <br />likely present in the coal mine waste should be added to the required characterization. Standardized <br />tests must be used to provide relevant data (see GARD Guide, 2016). <br />If warranted by the static tests, conduct humidity cell tests of the waste material to determine long- <br />term estimations of the weathering, neutralization, and leaching potential of the waste material. This is <br />imperative since the waste pile will essentially be left in place long after the mine is gone and the <br />reclamation bond is returned. Pollutants may continue to leach from the pile for years after the mine is <br />closed unless a proper design for containment is implemented. It is impossible to evaluate the waste <br />pile design for proper containment without this vital information (static and kinetic waste <br />characterization information) especially in light of the newest GCC proposal under TR20 to actually <br />reduce the four foot plant growth medium cover requirement to a mere two feet. Two feet of cover <br />material, depending on water holding capacity of the material, most likely will not even hold the average <br />annual moisture recharge to the soil from snowmelt and precipitation. <br />Finally, require and immediately implement a water monitoring system that effectively monitors <br />quantity and quality of surface water runoff or leachate from the waste pile and thus, the effectiveness <br />of the waste pile design. The design cannot possibly be evaluated or determined after waste placement <br />without an effective water monitoring system that ensures that design parameters were followed and <br />are working correctly. <br />GCC should further specify where mine waste is being stored within the mine permit area and the <br />nature of that material (whole elemental analysis, geochemistry, mineralogy, humidity cell tests, <br />monitoring). It is unclear whether the mine waste pile near the King I portal is the only area in which <br />mine waste is being stored or disposed. It is possible that mine waste is being stored in underground <br />sections of the King I and King 11 mines and, if so, these areas should be evaluated and monitored as <br />well. <br />Sincerely, <br />Carl B. Mount, M.S. <br />6175 W Ohio Ave <br />Lakewood, CO 80226 <br />M(, Lvkc Danielson, l' sq, Page 4 <br />King I and It Mine %fatpir and Coal Minp Wastp Concerns <br />May 11, 2016 <br />