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Memo to Jim Stevens <br />Rimrock Geotechnical Adequacy <br />page 2 <br />4. The operator eludes to both a permanent spoil pile and a temporary <br />overburden storage pile at various locations throughout the application. <br />It is logical that some spoil storage will be necessary to develop the <br />initial 1.5 acre pit. A permanent Excess Spoil Pile can only be <br />approved, in accordance with Rule 4.09, if the material is not required <br />to achieve approximate original contour within the mined area. Based <br />upon the limited material balance information contained within the <br />application, it appears that a deficit of bulked spoil will occur rather <br />than an excess. I can imagine numerous scenarios for material movement, <br />which result in temporary storage of spoil for later regrading. The <br />operator will need to amend the application to present a clear plan for <br />the movement, storage and placement of spoil materials during the project <br />life. A projection of mass balance, including projected bulking of <br />excavated material should be included within the application, in <br />accordance with Rule 2.05.3(6). If spoil storage is anticipated, the <br />applicant should also provide the information necessary to comply with <br />those requirements, also contained in that same rule. <br />5. The discussion of mine facilities is inadequate to satisfy the <br />requirements of Rule 2.05.3(3). The applicant should thoroughly describe <br />the intended surface facilities, including a map of the intended <br />configurations. Items such as all structures, conveyors, coal storage <br />piles or structures, coal waste storage piles or structures, non-coal <br />waste storage and disposal, shops, and any loadout facilities should be <br />described and located. <br />Sealing and Managing Mine Openings (Rule 2.05.4(2)(9) <br />The applicant intends to intercept old underground mine workings of the <br />abandoned C,F & I Engle Mine. Based upon the geological structure and <br />the mention of mine drainage being a component of base flow in Engleville <br />Gulch, it is likely that water may be encountered in the exposed <br />workings. The applicant will need to develop an alternative seal for use <br />in the event that water is encountered in exposed workings. <br />Use of Explosives (Rules 2.05.3(6)(a) and 4.08) <br />1. In general, insufficient information is provided to satisfy the general <br />narrative requirements of Rule 2.05.3(6)(a). The applicant doesn't <br />clearly state the maximum number of holes to be fired simultaneously. <br />There is no discussion or map location of explosive storage facilities. <br />There is a mention, but no elaboration of types of monitoring <br />seismographs to be used. Their is no explicit presentation of drilling <br />patterns, delay configurations, and separate hole loading. The applicant <br />will need to provide a clear and detailed discussion of all the topics <br />required under Rule 2.05.3(6)(a). <br />