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<br />37 <br />(5)Confirmation of the suitability of the stability analysis presented in this report for each <br />fill, or completion of a site specific re-analysis, <br />(6)Evaluation and monitoring of constructed fill to confirm design assumptions (spoil <br />density and sheaz strength), and verify stability. Monitoring could consist of verification <br />of initial spoil placement methodology. compaction testine during~lacement, slope <br />stabiliri monuments on final slopes, consolidation/settlement monuments on bench <br />surfaces, monitorine of flow from drains, monitorine of any seeps on or near fills, and <br />ground water well(s) near the toe. <br />CTL/Thompson included a discussion of the necessity of conducting equally extensive and <br />comprehensive investigations for all 21 proposed fills. Page 16 of Exhibit #13 states; <br />"The scope of investigation and design should evolve as investigations are completed." <br />Each fill must be the subject of an appropriate reconnaissance, design, stability analysis, <br />inspection, and monitoring program. A Division decision regarding whether the <br />preliminary stability analysis submitted within Exhibit #13 sufficiently characterizes any <br />parliculaz fill can not be completed by the Division until the results of steps (1) and (2) <br />have been provided in wnjunction with the operator's justification for reliance upon the <br />generalized parametric analysis for each fill. <br />Conclusion <br />Rule 4.09 requires that spoil fills be designed to ensure static slope stability factors of <br />safety of 1.5 or greater. CTL/fhompson concludes, as a result of it's preliminary <br />parametric (sensitivity) analysis; "The stability analysis indicates stable 511s meeting <br />CDMG requirements should be possible at the locations and configurations planned." <br />I agree with this statement. However, this demonstration is insufficient to allow the <br />Division to approve any of the 21 fills preliminazily proposed and depicted on Map <br />2.05.3-1 of the application. The operator will have to submit a site specific <br />application completely addressing additional investigation items (1) through (5) for <br />each fill, above, before the Division can approve construction of the fill. <br />Rule 4.14 Backtillipg and Grading <br />184. Cross-section locations should be spotted on a map and match the scale of the map <br />exactly for direct overlay. Map 2.05.4-1 Surface Mine PMT should have cross-section <br />Vocations depicted as well. <br />185. The annotation for Fill 1 on cross-section 43+50 does not fit with the location of Fill 1 <br />on the PMT map. <br />Rule 4.15 Reveeetation <br />