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<br />99. It is stated on page 2.05-39 of the application that "LCC has used the modified scaled <br />distance equation to determine the number of blast holes per delay...". The word <br />"modified" should be removed, as the equation used by the applicant is the same as the <br />equation found in Section 4.08.4(]0)(c)(i) of the Board's Regulations. "Modified <br />equations", discussed in Section 4.08.6(2), aze those that are a modification of this <br />formula, and that aze approved by the Division only after the Division receives <br />seismograph records of test blasts confirming the accuracy of the modified equation. <br />100. Please provide somewhere on page 2.05-37 a commitment that the applicant will comply <br />with the requirements of Section 4.08.3 regazding public notice of blasting schedules. <br />Please describe which newspaper will be used and include reference to which local <br />governments and public utilities will be notified. <br />Rule 2.05.3(7) Operation Plan -Coal Handling Structures <br />101. This section was found in compliance with the Rules. <br />Rule 2.05.3(81 Operation Plan -Coal Mine Waste and Non-coal Processing Waste <br />102. Page 2.05-40 of Volume 1 of the permit application states; "Coal processing will be <br />conducted at the existing permitted New Elk Mine under approved Permit C-81-012. No <br />coal waste will be generated by the Lorencito Canyon Mine." <br />In order to be accurate, this statement should read; "Processing of product coal from the <br />Lorencito Canyon Mine will be conducted at the existing permitted New Elk Mine under <br />approved Permit C-81-012. Coal waste generated by the processing of the Lorencito <br />Canyon Mine coal will be disposed of within the Coal Refuse Pile at the New Elk Mine. <br />No coal waste will be generated or disposed within the Permit area of the Lorencito <br />Canyon Mine." <br />The approved coal waste disposal plan for the New Elk Mine includes a coal refuse pile <br />designed in accordance with the requirements of Rules 4.09 and 4.10 of the regulations. <br />As such, the permit documents, as revised, include a thorough analytical demonstration <br />of the pile's slope stability. This analysis is based upon density and shear strength <br />parameters demonstrated to be appropriate for the waste generated by the processing of <br />product coal produced from the New Elk Mine. Before coal processing waste generated <br />from processing of product coal from the Lorencito Canyou Mine can be disposed <br />of within the New Elk Mine coal refuse pile, the operator of the New Elk Mine will <br />have to amend the New Elk Mine permit to allow this activity. <br />In order to obtain approval to dispose of Lorencito Canyon Mine coal processing waste <br />within the New Elk Mine's coal refuse pile, the operator will have to demonstrate <br />compliance with the requirements of Rule 2.05.3(8) in it's entirety. At a minimum, <br />sufficient laboratory testing will have to be completed to demonstrate that the shear <br />