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Memo to Tony Waldron <br />Bowie fJo. 2 Geotechnical Adequacy <br />page 7 <br />not be totally reclaimed." As with all the roads, benches and surface facility <br />disturbances at this challenging site, BRL will have to propose specific <br />reclaim~sd configurations. Cuts and embankments proposed to be retained as <br />part of the reclaimed configuration will have to be analyzed to demonstrate <br />their structural and geomorphic stability. Particular attention will have to <br />focused upon the drainage facilities because of the deleterious effects of <br />introdu~:tion of water to landslide landforms. In the case of the Mount Gunnison <br />No. 1 rnine, stability analyses determined that many of the retaining walls along <br />roadways and portal bench cuts need to be backfilled in place to attain stable <br />final reclaimed slopes. <br />Conduct of Mining Within 100 Feet of the Right-of-Way <br />BRL requests approval to conduct mining activities within 100 feet of the <br />historic right-of-way of old State Highway 133. Facilities such as a portion of <br />the Haul Road Loop, sediment pond B, and the road to the gob pile are within the <br />normal reserved buffer zone. In addition several private neighboring residences <br />are located close to the Highway right-of-way. The haul road exits onto old <br />State Flighway 133 at a 130° immediately opposite neighboring residences. No <br />comprehensive discussion of the probable impacts due to fugitive dust or noise, <br />or possible safety risks due to shared use of the Highway by haul trucks and <br />local residents is contained within the permit documents. Because BRL is <br />requesting a specific variance, BRL should propose methods to mitigate the <br />potential impacts and safety risks. <br />2.05.3(6) Overburden (Including Blasting) <br />On page 2.05.40, under section Z.05.3(6)(a)(v), BRL States; "Since this surface <br />blasting plan is applicable to surface blasting activities incident to <br />underground mining activities, the written notification will only be given to all <br />residents or owners of dwellings or other structures located within one-half <br />mile of the blast site." BRL has projected that blasting will only be required at <br />sites high on the haul road and upper bench facilities. BRL should be aware that <br />if they are incorrect in this assumption, they could be delayed thirty (30) days <br />while completing notification of any residents unexpectedly within one half <br />