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<br />June 28, 1995 Page 3 <br />Question: The western expansion area includes construction of <br />an underdrain. Has this construction been completed? If so, <br />the quarterly report should be revised to include the above <br />required information. <br />~* According to information added to Exhibit 18 with the approval <br />of Technical Revision No. 14 in 1992, lifts are being constructed <br />in two foot lifts. According to the 1982 RMG report, lifts were to <br />be constructed in three foot lifts. The quarterly inspection <br />report does not include any information regarding if the lifts are <br />being compacted to attain 90 percent of the maximum dry density. <br />This information is not contained within previously submitted <br />reports contained in the Division files. The report does not even <br />include minimal information, such as, "A lift was completed and a <br />compaction test was performed. The test meets 90 percent of the <br />maximum dry density." According to Appendix B, Compaction Testing <br />Schedule, added to Exhibit 18 following approval of Technical <br />Revision No. 15 in 1993, documentation of site conditions, test <br />locations, testing methods, and compaction test results will be <br />prepared and maintained in EFCI's files. Giving EFCI the benefit <br />of the doubt, I would assume the results of the compaction tests <br />are located at the mine office. However, given the history of <br />concern regarding the stable construction of the refuse pile at the <br />Southfield Mine, these reports should be submitted to the Division <br />with the quarterly inspection report. <br />Question: Pursuant to Rule 4.10.2(2)(b), the operator should <br />submit compaction tests to the Division on a regular basis. <br />In addition, all previous compaction tests should be <br />submitted.' <br />~* Appendix B, Compaction Testing Program, in Exhibit 18 was <br />approved in Technical Revision No. 15 which addressed a variety of <br />issues as the result of a midterm review. In reviewing <br />correspondence related to TR~15, I do not believe this plan <br />received a thorough review (i.e. there is not a memo or <br />documentation of a conversation in the file from one of our <br />geotechnical experts). I believe the testing program is inadequate <br />and there is nothing in the permit to suggest that it is. For <br />example, I am not sure that a certified professional engineer <br />prepared the testing program or reviewed it. While Rule 4.10.4(3) <br />does not indicate how often a dry density test should be performed, <br />it is typical to perform a test after completion of a lift. I <br />would think this testing frequency is important at the Southfield <br />waste pile given the variability of the waste that ends up in the <br />pile. EFCI's testing program only commits to doing compaction <br />tests on a semi-annual basis. Given their current plan, a <br />compaction test should have been completed during the first <br />