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<br />-18- <br />satisfy the requlatocy requirements of Rules 2.06.7 and 4.22. <br />Stability analyses have been completed for alternative <br />configurations of both the highwall and the existing spoil <br />slope in the vicinity of the proposed Foidel Creek mine's <br />portals. The applicant has also submitted a stability analysis <br />and engineer design for the temporary stockpile surface <br />facility berm area. <br />In order to bring this portion of the application into complete <br />compliance with the existing regulations, the applicant should <br />resolve the following issues: <br />1. Exhibit 8 contains a statement differentiating between <br />the current 3 to 5 year experimental nature of the mine <br />proposed fo[ consideration (see page 4 of Exhibit 8) and the <br />possible long term mine plan. The applicant should clearly <br />state its intent within the application. The configuration <br />proposed in Map No. 3, No. 4 and No. 15 represent modifications <br />from the alternatives analyzed and recommended within the <br />consultants report, Exhibit B. The spoil elope maximum grades <br />are depicted as 1.5:1 (horizontal to vertical slope), which the <br />consultant recommended only for the short term plan. If the <br />applicant reapplies for a long term approval in the future, <br />this elope would require modification to conform with the <br />recommended elope gradient of 2:1 (horizontal to vertical <br />slope). This should be clearly understood by the applicant and <br />will be clearly stated within the Division's findings document. <br />2. Tha applicant's consultant, CTL/Thompson, Inc., performed <br />a stability analysis, presented in Exhibit H, which is in <br />keeping with the prudent state-of-the-art of elope stability <br />analysis. In completing this analysis, the consultant made <br />several material strength assumptions regarding the existing <br />spoils and underlying fireclay. These assumptions appear <br />warranted, Sf the amended properties are verified through <br />appropriate monitocinq of the modified spoil and highwall <br />slopes. In fact, CTL/Thompson, Inc., recommends periodic <br />inspection and monitoring of these slopes to assure proper <br />performance (see page 26 of Exhibit 8). The applicant should <br />prepare a monitoring p[ogram for the modified spoil and <br />highwall elopes. Appropriate survey monumentation should be <br />Lnstalled following construction, and monitored in conSunction <br />with periodic inspections performed on a mutually acceptable <br />frequency. This is particularly important in light of the <br />short term slope configuration being proposed within the permit <br />application for the current permit period and mine plan. <br />3. As stated in comment 8 in the Ponds Section of this <br />letter, the applicant's consultant states, within Exhibit B, <br /> <br />