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4. The volume of the old gob pile exceeded 25,000 cubic yards in June of 1933. The <br />old gob pile was reclaimed in September of 1983. (See the second page of the third <br />quarter 1988 inspection report attached to this memo); <br />Even though the volume of the old gob pile exceeded 25,000 cubic yards, the <br />operator did not get the old gob pile into full compliance with the regulations. The <br />pile was not covered with 4 feet of non-toxic non-combustible material, only I S <br />inches to 24 inches. The old gob pile outslopes were not at a slope of 2h:1 v, rather, <br />1.Sh:ly. And the top of the pile did not slope. (See the first page of the third <br />quarter 1988 inspection report attached to this memo); <br />6. The permit application does contain a couple of relevant permit commitments. In <br />Volume 6A, the permit application states that the old gob pile outslopes are to be <br />reclaimed at a 2h:ly slope. This was not achieved in the field. It also states that the <br />old gob pile is to be covered with 15 inches to 24 inches ofnon-toxic, non- <br />combustible material. This soil depth would be a variance from the regulatory <br />requirement of 4 feet of cover, 4.10.4(5), but, I found no reference to a . <br />demonstration that the lesser depth of cover would still be acceptable to the <br />Division. I do not believe this reduced depth of soil cover has been verified by the <br />Division. (See the two permit application pages attached to this memo); <br />It is unclear what the factor of safety is for the old gob pile. The information in the <br />permit application is very sparse; <br />8. Apparently, the Division did not enforce full compliance with the regulations as <br />had been required in the 1981 Findings Document stipulation. This might have <br />been because the stipulation had stated that the operator had 6 months from the <br />time the pile exceeded 25,000 cubic yards to bring the old gob pile into full <br />compliance, but the pile was reclaimed within 3 months; <br />Jim Stover, the operator's consultant, has requested direction from the Division <br />since he is reluctant to certify the old gob pile as having been built according to the <br />designs. <br />Attachments <br />c:\wp61 \bowie I \o Id~ob 1 <br />