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Review of Refuse Pile & Pond Reports July 19, 1995 Page 2 the inspection recommends that, "Variation in the characteristics of the coarse and fine refuse materials are to be expected, depending on changes in the mine geology and mining practices. The fine material should be sampled and tested to identify an acceptable range of plasticity characteristics. When high clay content material is encountered in the mining operations, it should be sampled and compared with this range, with selective placement of high plasticity materials in the pile to avoid adverse stability impacts." This recommendation appears to indicate that there is still a question regarding placement of refuse material in the pile, which further enforces the need to complete compaction tests each time a lift is constructed. EFCI should comment on Mr. Brent's recommendations. Rule 4.09.1(11) requires that if a certified report references the construction of the underdrain system and protective filters, that color photographs be taken during and after construction, but before the underdrains are covered with excess spoil. The report for first quarter 1995 indicates that the base area expansion has been completed for the advancing side (west) of the waste bank. The western expansion area includes construction of an underdrain. Has this construction been completed? If so, the quarterly report should be revised to include the above required information. 4. According to information added to Exhibit 18 with the .approval of Technical Revision No. 14 in 1992, lifts will be constructed in two foot lifts. The quarterly inspection report does not include any information regarding if the lifts are being constructed in two foot lifts or if they are being compacted to attain 90 percent of the maximum dry density as required. This information is not contained within previously submitted reports contained in the Division files. The report does not even include general information regarding if a lift or a compaction test was completed or the results of the test. According to Appendix B, Compaction Testing Schedule, added to Exhibit 18 following approval of Technical Revision No. 15 in 1993, documentation of site conditions, test locations, testing methods, and compaction test results will be prepared and maintained in EFCI's files. The Division assumes that EFCI's files comply with this commitment. However, given the history of concern regarding the stable construction of the refuse pile at the Southfield Mine, these reports should be submitted to the Division with the quarterly inspection report. Pursuant to Rule 4.10.2(2)(b), the operator should submit compaction tests to the Division on a regular basis. In addition, all previous compaction tests should be submitted. (See also .#`5) .