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<br />5 <br />the provision that CC&V submit a modification to the AGVLF reclamation plan within <br />180 days of the approval of AM-11. <br /> <br />RESPONSE: CC&V agrees with the Division that it will be unable to develop a detailed <br />reclamation plan for the AGVLF to meet the review process timeline. Therefore, <br />Newmont requests that the Division issue a conditional approval with a provision that <br />CC&V submit a modification to the AGVLF reclamation plan within 180 days of <br />approval of Amendment 11. <br /> <br />Volume III – Appendices 3 through 8 <br />30. Appendix 5 – Scope and Purpose Clarification <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 <br />bullet) states “CNI agrees that a FOS of 1.5 for failure mechanisms that may <br />impact critical structures is appropriate, provided no prior experience has <br />been gained in historical mining of slopes in rocks with the same rock mass <br />characteristics and strengths… ” where “…CNI advocates for a minimum <br />FOS of 1.3…” This response does not explicitly offer any “historical <br />mining” that would support the acceptance of a FOS less than 1.5 for this <br />area. Please provide analysis results for a failure surface daylighting on the <br />slope side of County Road 82 and if it is less than 1.5, provide support that <br />historical mining has provided appropriate testing of similar rock for <br />characteristics and strengths to achieve a FOS of at least 1.3. <br />ii. Attachment 8 (September 2016 submittal). The CNI Figure 6-32 Section <br />GH-6 Global Analysis and Geology (Looking NE) depicts a failure surface <br />which daylights a considerable distance on the opposite side of Teller County <br />Road 82 from the high wall in question, indicating the road itself may have a <br />FOS considerably less than 2.219. Again referring to the response to <br />Comment 31.b (second bullet), please provide analysis results for a failure <br />surface daylighting on the slope side of County Road 82 and if it is less than <br />1.5, provide support that historical mining has provided appropriate testing of <br />similar rock for characteristics and strengths to achieve a FOS of at least 1.3. <br /> <br />