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<br />recommendations or justify it's proposal to use a less stable, steeper pit wall overall <br />slope angle. <br />East Cresson Mine Stability Evaluation <br />The East Cresson mine pit wall stability evaluation, contained as section 2 of Appendix 5 in <br />Volume 3 of the Amendment No. 8 application was prepared as a portion of Amendment No. 7 <br />application in June of 1998. As such it has been previously reviewed and approved by the <br />Division. The Division found the evaluation and report to have been prepared by Adrian <br />Brown Consultants in accordance with the standards of pit wall stability evaluation. <br />CC&VG presents it's permit commitments to pit wall overall slope angles for the East Cresson <br />Mine within table 5-4 on page 49 of the "Project Description" in Volume 1 of the Amendment <br />No. 8 application. In my opinion, table 5-4 faithfully reflects the recommendations of Adrian <br />Brown Consultants. <br />North Cresson Mine Area Slope Stability Evaluation <br />The North Cresson mine pit wall stability evaluation, contained as section 3 of Appendix 5 in <br />Volume 3 of the Amendment No. 8 application was prepared by Adrian Brown Consultants. <br />The North Cresson mine area includes five separate mine pits, designated as "A Area", "B <br />Area", "C Area", "D Area", and the "East Cresson Extension". These mine areas are depicted <br />on figure No. 1 of the report. As such, it appears the first four of the mined areas ("A" through <br />"D") will be completely backfilled beneath the Squaw Gulch Overburden Storage Area. Once <br />backfilled their pit wall stability becomes a mute point to the Division. Prior to their being <br />backfilled, however, the Division is concerned in the unlikely event that mining were to cease <br />and the Division were to assume the responsibility of reclaiming the site. Portions of the <br />highwall of the East Cresson Extension mine pit will probably remain exposed as a portion of <br />the final reclaimed configuration for that mined area. <br />During their data collection and the completion of their evaluation, Adrian Brown Consultants <br />determined that the bedrock geology of the North Cresson mine area differs from that of the <br />Main Cresson and East Cresson mine areas. The North Cresson mine area contains a "schist <br />island", comprised of Precambrian biotite gneisses and schists. These materials are <br />potentially weak, due to foliation and intense deformation. In completing the final <br />recommendations, Adrian Brown Consultants include an accommodation for schist materials <br />that form the northwest and southeast walls of the North Cresson "D" Area. The bench overall <br />slope angle is reduced to 45° to reflect the lower anisotropic strength parallel to the schistosity <br />planes. <br />In addition, rock quality data (RQD) averaging 30% collected from the upper 200 feet of core <br />data in the North Cresson "A" mine area suggest that fractured bedrock in this zone may be <br />unstable. For this reason Adrian Brown Consultants also recommends an overall slope angle <br />of 45° for the uppermost 200 feet of the "A" area mine. The remainder of the North Cresson <br />mine area, including the East Cresson Extension area are found capable of maintaining stable <br />pit walls at an overall slope angle of 60°. <br />Adrian Brown Consultants summarizes it's slope design recommendations for the five North <br />Cresson mine areas, including the East Cresson Extension area, on page 35 of it's report. <br />CC&VG presents it's permit commitments to pit wall overall slope angles for the five North <br />Cresson Mine areas within table 5-6 on page 53 of the "Project Description" in Volume 1 of the <br />Amendment No. 8 application. However, CC&VG overlooked a commitment for slope <br />design of the East Cresson Extension mine area within table 5-6. CC&VG presents it's <br />commitments for slope design on pages 48 and 49 of the "Project Description" of Volume 1 of <br />