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<br />of the refuse pile was based on the placement of coal waste only. With the addition of subsoil to the <br />refuse material without prior approval, a violation of the permit application occurred. <br />The Division's decision concerning the lack of compaction testing on the lower twenty feet or so of <br />placed material is based on the Division's field inspection of February 2, 1998 and on the first quarter <br />1998 waste bank inspection report dated April 2=t, 1998. The first compaction testing was performed <br />on b(arch 5, 1993 but the field inspection on February 2, 1993 showed that at least twenty feet of <br />refuse material had already been placed on the refuse pile. The Division believes that compaction <br />testing should be performed on at least the one or two beginning lifts in order to confirm that the <br />compaction methodology is achieving the proper compaction. Subsequent compaction testing should <br />be performed when appropriate to confirm the success of the compaction efforts. The Division believes <br />that compaction testing after the first 20 feet or so of material has been placed is not desirable. <br />The abatement section of the Notice of Violation lists the possible avenues of approach in resolving <br />these issues. First, Bowie Resources can perform a reevaluation of the geotechnical stability of the <br />refuse pile using appropriately adjusted material strength characteristics to reflect lower density, in <br />order to determine whether the pile as-built will be stable. If this reevaluation indicates that a static <br />factor of safety of 1.5 will be achieved, then the permit application still needs to be changed to show <br />the addition of subsoil in with the coal waste. This change should be inserted into the permit <br />application with the submission and approval of an appropriate technical revision. <br />If this geotechnical reevaluation demonstrates that the revised static factor of safety is below 1.5, then <br />Bowie Resources will need to do the following: 1) redesign of the refuse pile to consider partial <br />excavation and reconstruction, and/or buttress addition; Z) submission and approval of an appropriate <br />technical revision; 3) implementation of the necessary reconstruction or design modifications; and, 4) <br />appropriate additional slope stability monitoring to verify success of the chosen remedial techniques. <br />As with the first approach to abatement, the permit application would need to be modified in a <br />technical revision to include the addition of subsoil in with the coal waste. <br />Please refer to all three pages of the Notice of V iolation form, and to the Regulations, for specific <br />information concerning the enforcement procedures. <br />If you have any questions concerning this Notice of Violation, please call me. <br />S'.^cerely, <br />(f D <br />se J. H~udash <br />Environmental Protection Specialist <br />Enclosures <br />ce:Jim Stover P.E.(J.E. Stover & Associates) w\enclosures <br />Larry Routten w\out enclosures <br />Jim Pendleton w\out enclosures <br />e:\ms97\bowie2\novlet 1 <br /> <br />