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' `t `. <br />Memo to Susan Burgmaier <br />Southfield Coal Refuse Pile <br />page 5 <br />verification requirements be retained for the coarse coal refuse lifts. If the <br />MSHA District Manager concurs and approves the variance in writing it would go <br />into effect. If the MSHA District Manager approves some different variance, <br />Southfield may submit the variance as a Minor Revision for our review. <br />TerraMatrix also proposes that compaction be tested using `proof-rolling". I do <br />not believe that proof-rolling is sufficiently quantifiable and reliable to <br />recommend its acceptance as an inspection technique for application to a coal <br />refuse pile. <br />TerraMatrix also states its opinion that quarterly inspections of the Southfield <br />coal refuse pile should be adequate, based upon the current low rate of waste <br />placement. I do not disagree with this conclusion, as long as the rate of mining <br />and waste deposition do not increase. Further, TerraMatrix proposes seven <br />specific items for inclusion within the inspection reports. <br />(1) `Inspection of the entire pile for any failures." - I concur <br />(2) `Inspection of the entire pile for any springs and seeps." - I concur <br />(3) "Confirmation of lift thicknesses and placement procedures." - I concur <br />(4) "Confirm the fine and coarse refuse material being placed is consistent <br />with the material type described in the stability analysis." - 1 concur <br />(5) Confirmation of compaction by proof-rolling using a loaded dump truck and <br />noting the deflection." - I do not concur -See above comment <br />(6) `Engineer's comments and/or recommendations." - I concur <br />(7) "Descriptions of actions taken by EFCI to remedy any problems noted by <br />the engineer." - I concur <br />