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<br />Memo to Christine Johnston <br />MCC 3rd Quarter 1995 Compaction Reporting <br />page 2 <br />the pertinent portions of the pile to determine whether adequate <br />compaction has actually been achieved. If the error is determined <br />to be graphical, the solution is much simpler. In that case <br />Mountain Coal should provide the Division a copy of the original <br />proctor test data sheet and a corrected curve. I recommend in any <br />case that the Division require that all future proctor test <br />summaries include the proctor test data summary. This information <br />would allow the Division to resolve any possible graphical <br />reporting problems expeditiously. <br />The proctor test summary report, included in the third quarter <br />lower refuse pile report, has one additional shortcoming. It <br />reports that method D was used to complete the test and bears the <br />note "Rock Correction". However, there is no notation of the <br />amount of material substituted in completing the rock correction. <br />In my memorandum of August 31, 1995, I included a recommendation <br />addressing this concern. I recommended that all proctor test <br />reports contain size gradation information for the 1/4" minus, 1/4" <br />to 3/4", 3/4" - 3", and the 3" plus fractions of the samples <br />analyzed. This limited size gradation characterizes the oversize <br />constituency of the sample being analyzed. Based upon the <br />intention for this sample to represent the overall waste, it <br />therefore simplistically characterizes the waste. <br />Field Density Testing Procedure Comments <br />In my memorandum of August 31, 1995, I also included a <br />recommendation intended to provide validation of each radioactive <br />probe field density determination performed. I recommended that <br />the technician excavate the detection sphere surrounding the probe <br />following the completion of each density determination performed in <br />order to determine the apparent proportion of coarse rock within <br />the measured zone. Manufacturer's recommendations for the specific <br />apparatus being used should be provided and adhered with. If the <br />estimated proportion of coarse rock exceeds the proportion <br />determined in performing the proctor analysis (portion of the <br />sample replaced as rock correction), that fact should be noted on <br />the report and the test should be repeated at a nearby location. <br />Characterization of the Lower Refuse Pile <br />In preparing this memorandum I completed a telephone conversation <br />with Kathy Welt of Mountain Coal Company. Ms. Welt indicated that <br />MCC recognizes the compaction determination difficulties inherent <br />to coarse grained materials. In fact, Kathy inquired as to the <br />procedure for demonstrating that the refuse is "durable rock", in <br />accordance with Rule 4.09.4. Frankly, I do not believe our <br />regulations or the OSMRE's ever anticipated a coal mine waste with <br />