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<br />-3- <br />2. The appllcatlon contains only a summary of the design methods for sizing <br />the sediment ponds and drainage ditches and associated culverts. In order for <br />the Division to confirm that the assumptions used to design these facilities <br />are correct, Storm King must incorporate all supporting calculations into the <br />permit application. <br />Topso7l - Rule 2.05.3(5) <br />1. The locations of soil sampling sites, and topsoil stockpiles, and soil <br />salvage depths for each soil type are not shown on the soils map. This <br />information must be Incorporated into the permit application. <br />Overburden - Rule 2.05.3(6) <br />1. The application fails to present a complete 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 />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 />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 appllcatlon states that a temporary loadout <br />site will 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 appllcatlon. <br />Coal Processing Waste and Non-Coal Processing Waste - Rule 2-05.3(8) <br />1. The appllcatlon proposes staged construction of a 300' high coal <br />processing waste slurry embankment. The application contains excerpts of a <br />preliminary geotechnlcal investigation of the proposed site for the <br />embankment, but falls to present the required detailed geotechnlcal <br />investigation or stability analyses. For a structure of this type and <br />magnitude, the application must contain thorough and detailed reports of <br />geotechnlcal 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 1s particularly concerned about the proposed utilization of Mancos <br />shale-derived borrow to construct the starter dam, as well as -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 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 />