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<br />Rule 2.05.3(2) Operations Description <br />In response to our earlier comment, requesting amendment to more adequately <br />address the proposal of several escapeways and raises daylighting at the <br />outcrop high on the Grand Hogback's northeast-facing slope, the applicant has <br />provided additional description of the planned facilities on pages 4-26 and <br />4-26a of the amended application. The amended response indicates that the <br />"... actual plans may vary to insure slope and entry stability". However, no <br />detailed designs, diversion or drainage plans, or reclamation plans are <br />provided for these proposed facilities. Based upon the amended application as <br />it currently exists, it appears that the Division will have to deny <br />construction of these facilities until adequate baseline information and <br />design engineering plans have been submitted, reviewed and approved. <br />Rule 2.05.3(6)(a) Use of Explosives <br />In response to our earlier comment, requiring an appropriate submittal in <br />response to the requirements of Rule 2.05.3(6)(a)(i) through (vii), the <br />applicant has submitted additional information. The amended application's <br />pages 4-63 through 4-63e satisfy those requirements. Storm King Mining, Inc. <br />has also indicated a proposed explosives bunker location on Figure 4.2-3 of <br />the amended application. <br />This portion of the plan is approvable, based on the commitments contained <br />within pages 4-63 and 4-63a of the amended application. In preparing our <br />eventual findings, we should include reiteration of Storm King's commitments <br />to conduct pre-blasting surveys of all structures within Riverbend <br />Subdivision, prior to conducting any blasting operations at the site <br />(page 4-63). <br />Rule 2.05.3(8) Coal Processin and Non-Coal Processin Waste <br />The applicant has responded to our comments contained within our earlier <br />adequacy review, which dealt with deficiencies contained in Appendix 3.3-3a. <br />The amendments are made in the form of amended pages to the original <br />consultant's report, prepared by Chen and Associates, Inc. However, nothing <br />was submitted in the supplemental submittals to attest that the report, as ry~„5 <br />amended, is still certified by Chen and Associates, Inc. The applicant sWeu].d <br />submit a certification statement prepared by Chen and Associates which <br />certifies the consultant's authorship of the amendments. The following <br />comments assume receipt of that certification statement. <br />(1) The applicant has performed a pseudo-static seismic stability analysis <br />of the proposed life-of-mine configuration for the 300' high coal <br />processing waste slurry embankment. The applicant has applied a <br />horizontal acceleration factor of 0.1, as recommended by Mr. Rahe Junge <br />of the Colorado Geological Survey. Unfortunately, the analysis <br />performed determined the pseudo-static slope stability safety factor of <br />the life-of-mine structure to be 1.1. Rule 4.11.5(3)(a)(ii) <br />specifically requires that the seismic safety factor for such <br />structures "be at least 1.2". The applicant will have to amend the <br />engineered design, in order to achieve the required seismic safety <br />factor. <br />