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• requirement to cover refuse and coal processing waste materials with four <br />feet of cover has absolutely no scientific basis for Colorado, but is based <br />up a design standard developed by OSM for the eastern producing coal regions <br />of the country. Abundant research has been generated that casts serious <br />doubt on the universality of this standard. Due to the dubious basis of this <br />standard and information documenting that western coal waste materials have <br />properties that are significantly different than those materials in the <br />eastern coal producing provinces, it is recommended, that EFMC conduct a more <br />detailed evaluation the refuse materials to determine whether or not such a <br />cover requirement is necessary. This comparison is clearly defined in 30 CFR <br />816.85 and in the Colorado Regulations at Rule 4.10.4 as consisting of <br />"physical and chemical analyses" of the waste materials. Such a comparison <br />could eliminate the need for the four feet of cover required by the existing <br />regulations. However, in the mean time there is nothing to suggest that the <br />properties of the overburden and bench materials would diminish the <br />suitability of these materials as cover material. <br />• <br /> <br />9 <br />