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• <br />INTRODUCTION <br />The Southfield refuse disposal facility was originally designed according <br />to the Colorado Mined Land Reclamation Division requirement that all coal <br />processing waste be covered with the minimum of four (4) feet of non-toxic <br />and non-combustible materials. Refuse pile expansion operations in the past <br />several years have experienced substantial difficulties in obtaining enough <br />topsoil and refuse cover material (sub-soil) from the base area of the <br />proposed refuse pile to achieve the design goat of four (4) feet of cover. <br />Consequently Energy Fuels Coal, Inc. (Energy Fuels) began questioning the <br />validity of utilizing four (4) feet of cover over the refuse disposal facility. As <br />a result, Energy Fuels undertook the task of characterizing the Southfield <br />Mine refuse materials to determine 'rf, in fact, they are acid and toxic forming <br />as assumed in the regulations. Energy Fuels contracted with IME of Yampa <br />Colorado to conduct a detailed I'derature review concerning the validity of the <br />four (4) foot cover requirements, evaluate all refuse, soil, overburden and <br />other relative information contained in the Southfield Mine permit documents <br />and to conduct addftional refuse and soil material sampling and evaluations <br />to determine 'rf the reclamation plan, specifically four (4) feet of cover, could <br />be modfied at this site. <br />The resuRs of this process are presented in detail in this report and <br />• indicate that the Southfield Mine refuse materials are suitable as a plant <br />growth medium and that optimum reclamation of the site can be achieved <br />wkh replacement of 16 inches of topsoil material. <br />Unfortunately very little scientific justification exists to support the <br />assumption that coal processing waste materials in Colorado are acid and <br />toxic forming as presumed by the CMLRD Regulations. The purpose of this <br />evaluation will be to address the chemical and physical properties of the <br />Southfield Mine coal refuse materials and determine the necessary amount <br />of cover soil necessary to achieve successful reclamation. This evaluation will <br />be based on the actual properties of these materials and subsequent <br />scientific literature which has been generated relative to the characteristics of <br />western reclamation conditions since the four foot cover standard was <br />originally adopted by OSM. This approach is necessary because the ultimate <br />source of the Colorado requirements dealing with the reclamation of coal <br />waste materials originates with the regulations initially issued by the OSM in <br />the Federal Register of March 13, 1979. A careful examination of the <br />technical literature utilized by the OSM in drafting this requirement reveals that <br />183 references were consuRed during the formulation of this standard. <br />Unfortunately, none of these references was relative to the characteristics of <br />western coal refuse materials. Therefore, the mandating of regulatory design <br />standards applicable to successful reclamation of eastern coal refuse <br />materials to all western coal refuse materials is highly questionable from a <br />regulatory as well as a technological standpoint. Numerous examples could <br />be cited demonstrating that the conditions encountered in western coal <br />• mining are significantly different than those encountered in the eastern coal <br />producing regions. <br />