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i <br />Susan Mowry <br />-2- <br />May 26, 1987 <br />a small proportion (10-15%) of the material in the waste pile is made up of <br />coarse fragments less than 3" in diameter. These conditions do not pose a <br />severe threat to revegetation success. However, the application does not <br />contain an analysis of the percent of combustible material present within the <br />pile. Since the threat of spontaneous combustion is a legitimate concern for <br />waste pile reclamation, analysis of combustible material is critical. <br />I would expect that a soil cover of 18 - 24" would be sufficient for <br />revegetation success while minimizing surface erosion and perhaps the <br />potential for spontaneous combustion. It is unlikely that the Division would <br />approve a 6 to 12" cover as proposed in the revision application. <br />To resolve the dilemma of how much cover is actually necessary for waste pile <br />reclamation, I recommend that the operator prepare an application for <br />Experimental Practice, in accordance with Rule 2.06.2, and continue the <br />application of 24" cover. The operator may wish to propose test plots of 12, <br />18, and 48" cover on south and north facing slopes. Test plot design should <br />allow for the statistical comparison of cover depths and aspects. The <br />experimental practice application should contain a detailed monitoring program <br />to evaluate erosional status, incidence of fires and hot spots, and <br />revegetation success, based on concurrent reference area data. The <br />application should also contain an analysis and interpretation of percent <br />combustible material present. <br />Two other alternatives exist with respect to the amount of cover needed to <br />ensure reclamation success. The operator may propose new test plots for cover <br />depth and aspect on the existing waste pile and cover the remaining portion of <br />the waste pile with 4 feet of cover until reliable test plot results are <br />obtained. Or, the operator may cover the entire waste pile with 4 feet of <br />cover and comply with Rule 4.10.4(4). <br />/lal <br />9995E <br />