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• <br />• <br />• ~~ <br />6 <br />coal will be highly durable. It is also anticipated that a <br />significant quantity of trash, such as brattice cloth and <br />timber, may be included in the pile. <br />Based on our understanding of the composition of the <br />waste rock pile, we believe it potentially could be classi- <br />fied as coal processing waste according to Colorado Mined <br />Land Reclamation Board regulations. These regulations define <br />coal processing waste in Section 1.04 (24) as "earth <br />materials which are combustible, physically unstable, or <br />acid-forming or toxic-forming, which are wasted or otherwise <br />separated from product coal, and slurried or otherwise <br />transported from coal processing plants, after physical <br />processing to separate the coal from its impurities and <br />other activities necessary for the beneficiation of coal <br />into a saleable form." <br />Chemical analyses on roof, coal, and partings from <br />within the coal, as detailed in Appendix B, indicate that the <br />concentrations of most chemicals tested for appear to be <br />relatively low. Since Colorado MLRB regulations do not <br />specify chemical concentrations which constitute acid-forming <br />or toxic-forming materials, we have used idyoming Department <br />of Environmental Quality (DEQ) Guideline No. 1 to assist in <br />the evaluation of the physical and chemical character of the <br />materials of the waste rock pile. This guideline is intended <br />principally for the disposal of overburden from surface <br />mines; its use for this project was suggested by staff of <br />Colorado PILR. <br />The concentrations of some components fall within the <br />unacceptable range for disposal of materials close to surface <br />and/or in contact with water. The sodium absorption ratio <br />(SAR) for all samples is particularly high, ranging from 57 <br />- 18 - <br />GEO-MYDCO CONSULTING, INC. <br />