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i • • <br />Completeness Comments -3- <br />2. The application fails to present any discussion of anticipated blasting <br />~ activities. It is realistic to expect that blasting will be necessary to <br />/complete portal and associated surface facility construction. <br />J Rule 2.05.3(6)(a) requires the inclusion of a blasting plan within the <br />application which complies with the requirements of Rule 4.08. <br />Coal Handling Structures - Rule 2.05.3(7) <br />1. Page 4-18 in Volume 1 of the application states that a temporary loadout <br />site u111 be required to facilitate coal shipments during early development. <br />The information required by Rules 2.05.3(7), 2.06.10, and 4.28 must be <br />incorporated into the permit application. <br />Coal Processing Waste and Non-Coal Processing Waste - Rule 2-05.3(8) <br />1. The application proposes staged construction of a 300' high coal <br />processing waste slurry embankment. The application contains excerpts of a <br />preliminary geotechnical investigation of the proposed site for the <br />embankment, but fails to present the required detailed geotechnical <br />investigation or stability analyses. Fora structure of this type and <br />magnitude, the application must contain thorough and detailed reports of <br />geotechnical investigation, stability analyses and engineered design, in <br />compliance with requirements of Rules 2.05.3(8), 4.09, 4.10, and 4.11. <br />More specifically, as a result of the preliminary completeness review, The <br />Division is particularly concerned about the proposed utilization of Mancos <br />shale-derived borrow to construct the starter dam, as well ast -2" to +28 mesh <br />"coarse materials" to construct the phased embankment. We suspect that both <br />these materials may be subject to long-term slaking and significant material <br />strength degradation. Detailed anlyttcal presentations will be necessary to <br />alleviate these and other specific technical concerns regarding the <br />structure's operational and long-term stability. <br />2. The applicant has not addressed the requirement of Rule 4.10.4 for <br />placing four feet of the best available, non-toxic, non-combustible material <br />on the coal processing waste pile. The only mention is that two feet of <br />topsoil will be placed on the pile. There is no evidence provided that this <br />is sufficient cover to meet revegetatlon success standards. The permit <br />application must be updated with the appropriate information. <br />Underground Development Waste - Rule 2.05.3(9 <br />1. Because of the hydraulic mining technique proposed, all normal <br />~ underground development waste, such as partings, splits and roof and floor <br />rock, will be separated from product coal as processing waste and is, <br />therefore, appropriately addressed under Rule 2.05.3(8). However, the initial <br />portal and mine access development involves the construction of parallel <br />2,500' long rock tunnels, which will produce approximately 25,000 cubic yards <br />of underground development. The applicant fails to present any discussion of <br />the disposition of this and any other expected underground development waste <br />materials. <br />