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Page 2 of 4 <br />prior to construction. This design will be required to include inspection and evaluation of the existing drain to <br />determine its suitability for extension. <br />Subsurface Material Characterization <br />Section 5.1.3 of the SSA does not expressly state the slimes are not susceptible to earthquake- induced <br />liquefaction, and does not consider the potential for loss of strength due to elevated pore pressures, even though it <br />appears that a substantial deposit of this material will underlie the dam at a significant depth. Please address. <br />Section 5.1.4 of the SSA: The description of the sludge layer location is somewhat confusing. The layer is <br />estimated to be up to 3' thick at the beach at the upstream end of the current pond (1200' from the dam), <br />increasing to about 30' thick at the "back" of the pond. Figure C -1 (Appendix C) shows the "back" of the pond to <br />be farther upstream than the beach upstream of the dam, so the sludge layer does not appear to underlie the <br />projected final dam. Please clarify. <br />Seepage Analysis <br />Section 6.3 of the SSA: The description of the calibrated model as using a phreatic surface 1 foot below the latest <br />reading from Piezometer TH2006 -5 -1 (upstream of the blanket drain) but 8 feet above the highest reading for <br />Piezometer P -4 (downstream of TH2006 -5 -1, and which appears to penetrate the blanket drain) is somewhat <br />confusing. Is the highest reading in P -4 the latest reading? Using a higher phreatic surface would be <br />conservative, but the description appears inconsistent. Piezometer locations are not shown on the model results. <br />Please clarify. <br />Stability Analysis <br />In a seismic stability design criteria recommendation submitted by Climax to DRMS dated January 22, 2008, the <br />proposed design criteria stated that existing and future TSF design would be evaluated for stability under two <br />levels of design earthquake events: the OBE (Operating Basis Earthquake) for the operational period of the <br />facility, and the MDE (Maximum Design Earthquake) for the post closure period; with the MDE being set equal <br />to the MCE (Maximum Credible Earthquake). These criteria were accepted by DRMS in an approval letter to <br />Climax dated February 14, 2008. <br />The proposed seismic design criteria submitted for the Mayflower TSF are based on a magnitude 7.0 OBE event <br />with a return period of 475 years. The calculated seismic acceleration from the selected OBE event is 0.06g. <br />From Table 2 -1, the calculated peak horizontal acceleration during a 5,000 -year event (required for a large high <br />hazard water impoundment dam) would be 0.20g and the peak acceleration for a 10,000 -year event (generally <br />equated with the MCE) would be 0.27g. No data have been provided to show how the TSF design would <br />withstand a post - closure MCE event. Please provide a suitable evaluation as was done with the OBE event. <br />Section 7.4 of the SSA, Table 7 -3, lists the factors of safety against failure of the design slope under steady -state <br />and post- OBE earthquake loading. The post- earthquake analyses appear to have modeled the dam under static <br />loading conditions using the undrained soil strengths listed in Table 7 -2. While the design OBE and MCE ground <br />accelerations are listed, there is no discussion in the report of any analysis performed under transient seismic <br />loading. Please evaluate the stability of the existing and proposed Mayflower TSF under the OBE and MCE <br />seismic load, as approved in 2008, using undrained soil strengths. Please also evaluate the TSF under a varying <br />seismic load to determine what level of earthquake shaking the TSF will be able to withstand (if the TSF cannot <br />be shown to withstand the MCE). <br />SSA Recommendations and Monitoring /Reporting <br />DRMS will require that all bullet items listed in section 8.2 of the SSA be implemented and incorporated into the <br />monitoring and reporting program for Mayflower TSF. DSB has recommended that pore pressures in the slimes <br />under the construction of new berms and beaches also be closely monitored to minimize the risk of buildup of <br />excess pore pressure. Please describe how Climax intends to address this issue. <br />