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4. The first paragraph of the coal mine waste disposal piles inspection report states that <br />"The West Valley Fill has received some additional waste material during the third <br />quarter... Compaction tests are planned as materia- is added to the waste area." A <br />review of all reports dating back to the third quarter 2002 shows that the same <br />statement was in all of these reports. None of these reports gives a quantity of refuse <br />added to or removed from the pile and there is no compaction test data or text stating <br />that compaction testing has been performed (although the third quarter 2002 report <br />does state that compaction testing was performed on 26 August 2002 and 16 <br />September 2002 and the "Gob material has consistently passed compaction tests"). It <br />is unclear from the permit exactly what quantity of refuse or timing "triggers" <br />compaction testing. Rule 4.10.4(3)(b) states that "Compaction to attain 90 percent of <br />the maximum dry density... (is) required for stability of the coal mine waste bank." <br />The Division does not have any compaction test data for at least the last three years <br />and no note of compaction testing for the last three years. If compaction testing has <br />been performed, please update the report and provide compaction test data. <br />Additionally, if compaction testing has been performed at any time after the third <br />quarter 2002, please indicate this and forward the data to the Division for review. If <br />no compaction testing has been performed since the third quarter 2002, please <br />provide the Division a justification as to why OMLLC does not need to perform the <br />testing as required by the Rules. <br />5. As stated above, it is unclear what "triggers" compaction testing at the OMLLC <br />waste piles. This may be a permit deficiency that needs to be addressed by a revision <br />to the permit. Please provide an explanation to the Division stating when, why and <br />how compaction testing is performed. <br />II West Vallev Fill <br />6. On the Division's inspection on 25 October 2005 it was noted that there was minor <br />rutting on the haul road to the [I West Valley Fill. Please provide the Division with a <br />plan and timetable for fixing this problem. <br />Please call me if you have any questions or concerns at (303) 866-4929. <br />Sincerely, <br />James R Stark <br />Environmental Protection Specialist <br />