Laserfiche WebLink
<br />(3) In response to our original adequacy comments, the consultant <br />amended pages 39.3 thcough 34.7 of Appendix 4.5-1 to present <br />a more- comprehensive discussion of slope stability and <br />subsidence relationships on Coal Ridge. The amended <br />application observes that moderate slumping and landsliding <br />is limited to areas "outside and below the anticipated areas <br />of surface subsidence effects." (page 39.5) with the <br />exception of one questionable portion of the northeastern <br />face of Horse Mountain, the Division concurs with that <br />opinion. There appears, however, to be extensive geomorphic <br />evidence of ancient slope movements througout large portions <br />of the slopes on the northeast face of Coal Ridge. <br />On pages 41.1 and 41.2 of the amended Appendix 4.5-1, the <br />consultantdescribes a proposed visual monitoring program <br />which will specifically observe slope characteristics <br />considered indicative of slope movement, such as "...surface <br />cracking, movement of large rock blocks and the development <br />of bulging ground near the base of the slope." the amended <br />application's Appendix 4.5-1 also presents a detailed <br />proposed program for mitigation of slope stability problems. <br />Simplistically, in areas where no danger is presented to <br />structures, mine personnel or the public, the applicant <br />proposes to restrict access and visually observe manifested <br />slope instability phenomena. In any areas where a hazard <br />exists to structures, mine personnel or the public, the <br />operator will also, "...as necessary and appropriate, provide <br />slope stabilization techniques". As amended, however, <br />vagueness exists concerning the role of the Division in the <br />decision of whether or not a hazard to structures, mine <br />personnel or the public exists. To avoid possible future <br />disagreement, our eventual findings will impose a stipulation <br />which clearly states that the Division shall review and <br />concur with any decision of whether a hazard is represented <br />by any specific slope movement event and whether a slope <br />stabilizationprogram should be developed and implemented, <br />(4) It will be important to clearly present the results of the <br />visual and survey monitoring programs at the Coal Ridge No 1 <br />Mine. The amended application presents no detail regarding <br />the formate of the semi-annual subsidence monitoring reports. <br />In the interest of facilitating complete and efficient <br />presentation of the accumulated subsidence monitoring data, <br />our eventual findings will include a stipulation requiring <br />the submission of a proposed subsidence report format within <br />six months following issuance of the permit." <br />SKM Response: <br />