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<br />Rule 2.05.3(6) - Overburden <br />The application fails to present an adequate description of overburden <br />movement involved in the development of the numerous surface facilities at the <br />mine. In order to prepare acceptable bonding calculations the applicant will <br />need to provide a narrative and tabular description of earthwork quantities <br />and material movement and storage schemes. <br />The application also fails to present any discussion of anticipated blasting <br />activities. It 1s realistic to expect that blasting will be necessary to <br />complete portal and associated surface facility construction. <br />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 />The application is Incomplete in its response to Rule 2.05.3(6). <br />Rule 2.05.3(8) - Coal Processing Waste and Non-Coal Processing Waste <br />The application proposes staged construction of a 300' high coal processing <br />waste slurry embankment. The application contains excerpts of a preliminary <br />geotechnical investigation of the proposed site for the embankment, but falls <br />to present the required detailed geotechnical Investigation or stability <br />analyses. For a structure of this type and magnitude, the application must <br />contain thorough and detailed reports of geotechnical investigation, stability <br />analyses and engineered design, in compliance with requirements of <br />Rules 2.05.3(8), 4.09, 4.10 and 4.11. <br />More specifically, as a result of my preliminary completeness review, I am <br />particularly concerned about the proposed utilization of Mancos shale-derived <br />borrow to construct the starter dam, as well as -2" to +28 mesh "coarse <br />materials" to construct the phased embankment. I suspect that both these <br />materials may be subject to long-term slaking and significant material <br />strength degradation. Detailed analytical presentations will be necessary to <br />alleviate these and other specific technical concerns regarding the <br />structure's operational and long-term stability. <br />The application is incomplete in its response to Rule 2.05.3(8). <br />Rule 2.05.3(9) - Underground Development Waste <br />Because of the hydraulic mining technique proposed, all normal underground <br />development waste, such as partings, splits and roof and floor rock, will be <br />separated from product coal as processing waste and 1s, therefore, <br />appropriately addressed under Rule 2.05.3(8). However, the initial portal and <br />mine access development Involves the construction of parallel 2,500' long rock <br />tunnels, which will produce approximately 25,000 cubic yards of underground <br />development. The applicant falls to present any discussion of the disposition <br />of this and any other expected underground development waste materials. <br />The application is incomplete in its response to Rule 2.05.3(9). <br />