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Findings <br />I. Records Review <br />I reviewed design information in the mine plan and as provided by DMG. The Team <br />previously decided the review would assume approved designs comply with DMG's <br />rules. Only those permit provisions approved by DMG by the date of my review were <br />included in my review. I reviewed permit information at WRCC's Denver office, at <br />DMG's Denver office on May 23 and July 16, and at its Grand Junction office on August <br />4, 1997. We also reviewed information at the mine office on August 6, 1997. Design <br />criteria are summarized below for the respective refuse piles. <br />I reviewed engineer's inspection reports that were submitted to DMG over the period of <br />1986 through the second quarter of 1997 for the three piles. I reviewed a total of 125 <br />engineer's inspection reports. These reports typically were submitted to DMG quarterly <br />and after the end of respective quarters. In two cases, they were supplemented with an <br />additional report submitted within the quarter. Reports included descriptions of the <br />piles' conditions and addressed critical construction activities that occurred during the <br />respective quarters. Though I noted submittal dates for only 28 quarterly reports, by <br />comparing dates of refuse pile inspections with professional engineer's stamp dates <br />and dates of receipt by DMG, my review showed that 30 reports (24%) submitted from <br />1993 through 1996 weren't sent to DMG within two weeks after the inspection dates as <br />required by section 4.09.1(11)(b). Ninety-five others didn't have transmittal dates on <br />the file copies so I couldn't evaluate the timeliness of their submittal. <br />Engineer's reports submitted to DMG were revised slightly by the permittee during the <br />period reviewed. Reports submitted between 1986 and the third quarter of 1995 <br />included a checklist of items relating to the piles' physical condition. Those items <br />addressed compaction testing, burning, seepage, cracking, sloughing or bulging, <br />erosion, surface movement, and drainage. The reports also included space for <br />comments on adverse changes that could cause instability. Engineer's reports noted <br />the piles' status (e.g., refuse being added, bench completion, preparation for cover <br />material, repair of drainage systems, etc.) and their condition (e.g., no problems, usual <br />seepage, tilling, etc.). They assessed hazardous conditions (none were noted), and <br />occasionally made recommendations for monitoring and/or maintenance. Notably, pre- <br />third quarter 1995 engineer's reports didn't include a PE's certification that the fill(s) <br />had been constructed as specified in the design approved by DMG as required in <br />4.09.1(11)(b). Also, pre-third quarter 1995 engineers reports didn't include a <br />professional engineers (PE) seal that customarily accompanies a PE's signature. <br />Reports completed after the third quarter of 1995 included the same items describing <br />conditions noted above, another to identify any benches completed during the quarter, <br />and a second new item noting any certifications. Additionally, post-third quarter 1995 <br />reports included the requisite engineers certification and the accompanying seal. <br />4 <br />