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Memo to Susan Burgmaier <br />Southfield Coal Refuse Pile <br />page 4 <br />The goal of our regulations is to assure that coal refuse piles are stable. If <br />stable they will perform properly with minimal maintenance. Following <br />reclamation they should require zero maintenance. The Southfield refuse pile <br />receives waste at a low rate. This allows the fine coal refuse the time it <br />requires to consolidate and develop the shear strength necessary for the pile to <br />remain stable. <br />Conclusions and Recommendations <br />In my opinion, as long as appropriately conservative placement and monitoring <br />practices are applied to the construction of the Southfield Mine coal refuse pile <br />it will continue to perform properly. It is important, however, that proper <br />practices be followed. This same logic has been consistently applied by the <br />Division during repeated earlier reviews of requested revisions of the design <br />and specifications for the Southfield Mine's coal refuse pile. <br />TerraMatrix includes recommendations for compaction requirements and <br />inspection of the coal refuse pile within it's report. TerraMatrix recommends <br />that the 90% compaction requirement be waived for the coal refuse pile. Rule <br />4.10.4 of our regulations present the "Construction Requirements" for any coal <br />refuse pile. The requirements include placement in no greater than 24" lifts and <br />compaction to 90% of the maximum dry density. Subparagraph 4.10.4(3)(c) does <br />provide for the granting of variance in lift thickness and compaction <br />requirements, but only"...after approval of the variance by the Mine <br />Safety and Health Administration's (MSHA) District Manager, as <br />required by 30 CFR 77.215". <br />It is my recommendation that we propose to approve a variance in our regulatory <br />requirements to the extent that it concerns the placement of the fine coal <br />refuse. That is, the Division propose to approve placement of waste as follows. <br />Fine coal refuse may be placed in up to one-foot thick lifts. A lift of fine coal <br />refuse shall be covered with a lift of coarse coal refuse, not to exceed two feet <br />in thickness. The compaction and compaction verification requirements be <br />waived for the fine coal refuse lifts. However, the compaction and compaction <br />