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D,RMS SUPPLEMENTAL REPORT:Concerns in re COMPLIANCE RE BENCHING within HIGHWALL <br /> 12/6/18 MLRB 1978-208 Shaffers Crossing <br /> C%n n YLO <br /> REPORT: Notice of Inspection 3/13/18 <br /> Inspector Michael Cunningham <br /> Division of Reclamation Mining and Safety <br /> Response from Operator Prepared by MOORESJ, Min. Eng., CSM, BSc.Geol.,Geophysics(II), Elk Creek <br /> Companies, LLLP./S/Elk Creek,Sand&Gravel LLC <br /> Reviewed and Accepted/endorsed by BROCKMAN,S, PE Cave Eng. (license# ) <br /> Brockman Engineering Inc, Conifer CO 80433 <br /> 12/7/18 <br /> ISSUE <br /> Inspector notified Operator Representative on or around 3/13/18 that there was an issue relating to <br /> Inspection conducted in which Inspector indicated a concern that the bench configuration within the <br /> confines of the permitted and approved highwall design was not being followed. <br /> The inspector indicated that he had participated in site walk-through and in that walkthrough he made a <br /> number of observations:a)signage was insufficient and did not comply with the terms of the <br /> Regulations enforced under the Division Rules, b)that a weed control plan was absent from the <br /> Operators file or not otherwise sufficient and that the Division was requiring that the Operator provide a <br /> technical revision to its permit such that this addressed and conformed to the regulatory requirement <br /> under the Rules to include an acceptable weed control plan <br /> c)that the Inspector was unable to visually confirm that the Operator was complying with the stipulated <br /> bench configurations, particularly the bench width relative to the bench height, in order to conform to <br /> the recommendations presented under the geotechnical report filed om behalf of the Operator in 2006 <br /> (the Brierley Geotechnical and Slope Stability Analysis) <br /> This report addresses the issue specifically of the HIGHWALL BENCH WIDTH CONFIGURATION such that <br /> the specified configuration is an 8'-0" bench no 76 degree angle of repose,and the benches are 12'-0" <br /> by 35'-0" in the perpendicular(See exhibit FIGURE 10c 2006 BEI ODP Final USES and Plan PDF)wherein <br /> the final Bench design for the highwall submitted to and accepted by DRMS Board, based upon Division <br /> recommendations,complies with the calculations and toppling or over turning moment restrictions <br /> from the 2006 Geotechnical report <br /> SPECIFIC CONCERN BY DIVISION STAFF <br /> The specific issue that was a concern raised by Vision Staff is that the prescribed bench configuration as <br /> indicated,since it did not exist,would have to be implemented in order to bring the highwall into <br />