INSPEC09399

• Permit No: C1981012
• IBM Index Class Name: Inspection
• Doc Date: 7/8/1997
• Doc Name: OSM INSPECTION REPORT
• Inspection Date: 6/10/1997
• Media Type: D
• Archive: No

pass disturbed area drainage in a segment of the western side ditch of the RDA through
a sediment pond or facility. The notice had an abatement deadline of August 26, 1994,
and was eventually terminated by DMG.
Findings
1. Records Review
OSM's review did not evaluate approved designs for either refuse pile. The review
notes, however, that DMG's mid-term permit review dated April 1, 1997, found the
permit's information about the MWDP lacking. Specifically, DMG's discussion in its mid-
term review under section V, item 21 (page 9) said, "The currently approved permit
lacks the information required by Rule 2.05.3(8) for the development waste pile located
west of the main entrance. Both the text narrative and the information in Exhibit 30 is
inadequate.' Section 2.05.3(8) of Colorado's rules requires permit applications to
inGude a general plan and detailed design plan for each coal mine waste and non-coal
processing waste bank, dam, or embankment proposed to be constructed within the
permit area. According to DMG, the permittee's submittal of the requested information
is expected.
I reviewed engineer's quarterly inspection reports that were submitted to DMG over the
period of 1985 through 1996 for both piles. I also reviewed reports of critical
construction activities, such as underdrain construction, and a number of professional
engineers (P.E.) design certifications. Of the quarterly reports reviewed, 14 were
submitted to DMG within two weeks of the inspection date as required by section
4.09.1(11), and eight were submitted late. Eight others did not have transmittal dates
so the timeliness of their submittal could not be evaluated. The quarterly reports
inGuded categories corresponding to the critical construction periods described in
section 4.09.1(11)(a) that were checked off in most cases. Three engineers reports
from 1986 and 1990 certified that the RDA underdrain was constructed under the P.E.'s
supervision and in accordance with the approved design. I also reviewed a P.E.'s 1988
certification of the RDA side ditches in place at that time.
Quarterly reports noted the piles' status (e.g., idle, maintenance, lift construction,
compaction, construction of surface drainage system, and underdrain extension) and
condition. They assessed hazardous conditions (if any), and made recommendations
for monitoring and/or maintenance. In almost all cases, quarterly reports inGuded the
P.E.'s certification seal on the back. With the exception of the three RDA reports with
the P.E.'s certification of underdrain construction noted above, quarterly reports I
reviewed did not inGude a statement that the fills were constructed as specified in the
design approved by DMG as required in section 4.09.1(11)(b). They did, however,
inGude statements to the effect that lifts were constructed in layers two feet thick or
less, that slopes were no steeper than 2h:1 v, and that lifts were no higher than 50 feet.
Further, compaction testing conducted in 1995 and 1996 was documented in two
reports for each pile. Test results showed that 90% compaction was attained in most
2 1997 New Elk Special Focus