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Memo to Joe Dudash <br />Bowie No. 1 Mine's Old Waste Pile <br />page 2 <br />engineer would now require redisturbance of the pile. Material character and in-place <br />density would need to be determined. Materials would need to be collected and analyzed <br />in the laboratory to determine strength characteristics and optimum density relationships. <br />You have indicated that vegetation has become "very well" established on the pile. <br />Further, you observed that the pile appeared to be stable. Finally, you are concerned that <br />the cover material thickness did not equal the required thickness, but you state that the <br />vegetation has apparently succeeded. Certification would require test pits and/or auger <br />sampling, resulting in disturbance of the pile. If reconstruction were completed, the <br />treatment disturbance would be significant. <br />I realize that the regulations, both OSM's and the State's, require certification of the pile. <br />However, in my opinion, disturbance of this pile is only warranted if it is currently <br />exhibiting instability. Disturbance of the environment to determine whether the <br />environment might be at risk, while legalistically correct, should be justified in light of the <br />relative magnitude of the risk believed to exist. <br />If you desire, t could examine the pile at the first opportunity afforded by my schedule and <br />the meteorological conditions in the North Fork Valley. Realistically considering the <br />tenuous nature of both of these criteria, I believe I could complete an appropriate field <br />reconnaissance and provide an opinion by May 1, 1999. As an alternative, I could <br />complete a remote stereo aerial photographic examination of the pile utilizing whatever <br />stereographic aerial photo coverage the Division, the operator, and the operator's <br />consultant might possess. A photo reconnaissance and opinion could probably be <br />completed by March 1, 1999, dependent upon availability of adequate stereo aerial <br />photographic coverage. <br />If I discover evidence of existing instability within the waste pile, I can provide <br />recommendations on how investigation and certification should be conducted. If my <br />investigation does not discern evidence of instability within the old waste pile, I will <br />recommend that required activity by the operator be limited to appropriate monitoring to <br />verify stable performance. Further, the operator should be advised that any future <br />instability within the old waste pile would require remedial treatment. <br />cc: Larry Routten <br />Dave Berry <br />Doc: M:\COAL\JAP\Bow1 Pile.wpd <br />JP/1P <br />n.... .,. <br />