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Mr. Jack Henris <br />October 19 2016 <br />Page 4 <br />m:\min\tc1\_teller\m-1980-244 cc-v\am -11\m-80-244-am-11-2ndmaincomment2016-10-19r4combined.docx <br />response suggests trees will be planted to help control erosion. The 2,000 plus slope lengths <br />identified in the Division’s original comment are on the south and west side of the AGVLF. <br />Drawing CCVSA11-3 (in the reclamation cost estimate) indicates trees will be planted on <br />the north and east slopes, thereby providing no erosion protection for the long slope lengths. <br />Finally, pursuant to Rule 6.4.6(b), portrayal of the proposed final land use for each portion <br />of the affected lands shall be shown on the Reclamation Plan Map (Exhibit F, not Exhibit <br />L). Further review of the AGVLF reclamation plan indicates other aspects that need <br />clarification and/or demonstration that the reclamation goals can be achieved. As the <br />AGVLF has reached full build-out (the Division understands that only active leaching is <br />proposed for the remainder of the AGVLF life), it is imperative to begin addressing the <br />specific details of the AGVLF reclamation heretofore having been presented only in a more <br />conceptual plan. This expands the scope of AM-11 to a level that may not have sufficient <br />time to address within the 365-day limit of the AM-11 review process. As such, the Division <br />will consider a conditional approval of AM-11 (with respect to this comment no. 24) with <br />the provision that CC&V submit a modification to the AGVLF reclamation plan within 180 <br />days of the approval of AM-11. <br />25. Page 13-2, second paragraph – reclamation grading. Response is adequate. <br />26. Page 13-3, Section 13.2 Project Financial Warranty Requirements. Response is adequate. <br />27. Page 13-6, Section 13.8 Summary. The last sentence states “The overall costs will be <br />incrementally posted as disturbances occur”. Response is adequate. <br />Volume III – Appendices 3 through 8 <br />28. Appendix 3, Baseline Technical Report. There appears to be a large discrepancy in the <br />affected area boundary in Figure 1, specifically “Survey Area 2”… Response is adequate. <br />29. Appendix 4, Review of Blasting Studies at CC&V. CC&V’s commitment to monitor <br />underground blasting as recommended by MMC is adequate. <br />30. Appendix 5 – Scope and Purpose Clarification. <br />a. The inclusion of “NORTH AREA UNDERGROUND MINING AREAS” The <br />response explaining the analysis was completed prior to changes in the mine plan <br />being finalized for AM-11 is adequate. <br />b. Limits of potential highwall failure. The response is not adequate. The response <br />confirms the purpose of Appendix 5 is to satisfy the requirements of Rule 1.5. <br />However, the response fails to demonstrate the Division’s stated Factors of Safety <br />pursuant to Rule 6.5(3) are or will be met with respect to Teller County Road 82. <br />Please address the following: <br />i. Attachment 8 (September 2016 submittal). The CNI Figure 6-18 Section <br />GH-4 Global Analysis and Geology (Looking NW) depicts a failure surface <br />with a “FOS = 1.52”. The failure surface daylights on the opposite side of <br />Teller County Road 82 from the high wall in question, indicating the road <br />itself has a FOS less than 1.52. The response to Comment 31.b (second