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June 28, 1995 Page 2 <br />* The permit, in Appendix B of Exhibit 18 (approved in TR#15), <br />states that two compaction tests will be conducted at random <br />locations on each active fill bench. The tests will occur on a <br />semi-annual basis and will be scheduled to coincide with the first <br />and third quarter stockpile inspections. Documentation of site <br />conditions, test locations, testing methods, and compaction test <br />results will be prepared and maintained in EFCI's files. <br />* The approved method of construction is to complete two foot <br />lifts. One lift is made up of fine refuse, followed by one or more <br />lifts of course refuse. A violation was written in 1992 for <br />failure to construct the pile as designed, as the approved <br />construction plan specified a 3:1 coarse to fine mixture. EFCZ <br />provided stability analyses and plasticity values of coal refuse <br />(specifically fine refuse). EFCI was effective in demonstrating <br />that the refuse pile was stable with the 1:1 ratio of coarse to <br />fine disposal and that plasticity values of the material were low. <br />The Division agreed that further testing of the fine refuse <br />material was unnecessary. <br />Compliance and Adeguaov Questions <br />~* In general the timing of the inspection reports (i.e. when they <br />are completed and submitted to the Division) and the report <br />contents are in compliance with the above noted regulation. The <br />engineer inspecting the pile notes that the "coal processing waste <br />bank was visually inspected and found to be in general compliance <br />with CMLRD approved Reconstruction Plan for the Coal Processing <br />Waste Bank." I believe the engineer is referring to a report <br />entitled, "Reconstruction Plan and Storage Optimization" prepared <br />for Dorchester Coal Company by Rocky Mountain Geotechnical (RMG) in <br />1982. From review of Exhibit 18, I believe that portions of this <br />plan prepared by RMG has been updated. <br />Question: Is the engineer performing the inspection aware of <br />the design changes that occurred in 1992? The changes include <br />the depth of each lift and the disposal ratio of coarse to <br />fine material. <br />~* Rule 4.09.1{11j also requires that if a certified report <br />references the construction of the underdrain system and protective <br />filters, that color photographs be taken during and after <br />construction, but before the underdrains are covered with excess <br />spoil. The report for first quarter 1995 indicates that the base <br />area expansion has been completed for the advancing side (west) of <br />the waste bank. <br />