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III IIIIIIIIIIIIIIII <br />999 <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparlmenl of Natural Resources <br />1313 Sherman Si., Room 215 <br />Denver, Colorado 80203 <br />Phone. 1303) A66-3567 <br />FAX (303) A32 ft106 <br />DATE: August 31, 1995 <br />I~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />TO: Christine Johnston Governor <br />dames 5. Lochhead <br />FROM: Jim Pendleton - e.er°'Ive°"""°` <br />- Michael B. Long <br />Drviwun Duermr <br />RE: West Elk Min - Co 1 Refuse Compaction <br />(Pe C-80-007) <br />I have reviewed the collection of materials you forwarded to my <br />attention regarding the coal refuse compaction controversy at the <br />lower refuse pile at the West Elk Mine. That packet included <br />compaction reports and proctor test records since late 1994 and <br />several letters exchanged between the Division, Mountain Coal <br />Company (MCC), and MCC's engineering testing consultant, Lambert & <br />Associates. Candidly, in my opinion, the materials demonstrate <br />that a conceptual problem did exist, but has been solved through <br />the exchange. All that remains is to stipulate a few performance <br />requirements and the problem should not recur. <br />Administrative Background <br />This controversy has surfaced several times over the past decade. <br />MCC and its predecessor have consistently provided compaction <br />testing results supposedly documenting relative densities well in <br />excess of 100% (I found one in excess of 140%, Test #24, 12-27-94). <br />Frankly, while not impossible, results in excess of 110% defy <br />traditional wisdom. Therefore, it was appropriate for the <br />Division, particularly after reviewing the results of late 1994 <br />(12-27-94) and early 1995 (2-27-95), to formally express a quandary <br />and ask MCC to elaborate on its compaction findings (your letter of <br />March 7, 1995 to Henry Barbs). <br />MCC forwarded a response (letter from Kathleen G. Welt to you dated <br />March 20, 1995), including a memo from Norman W. Johnston, P.E. and <br />Dennis D. Lambert, P.E., both of Lambert & Associates. Messrs. <br />Johnston and Lambert present thoughts regarding the compaction <br />testing results from the lower refuse pile. Not atypically, I <br />agree with some of their observations, and differ with some, which <br />I'll address later. Since March of 1995, MCC has submitted two <br />more sets of testing results (4-27-95 and 6-13/16/19/95), in <br />accordance with their permit requirements for quarterly reporting. <br />