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5! <br />Mr. Edgar Hunter <br />15 November 19. 1992 <br />the structural fill, maximum thicknesses for the lifts to be placed, degree of compaction which <br />will 6e attained for each lift, upstream and downstream slopes and slope stability analyses, <br />primary and emergency spill-way details, etc. <br />7. Pit Wall Stability <br />The operator should submit details regarding pit design and pit wall stability. This submittal <br />should include the basis for designed overall slope angles, bench-face angles, bench width and <br />bench height. The analyses must consider whether you are dealing with wet or dry slope <br />conditions, the relationship between remaining intact rock bridges and the possibility of severe <br />blast damage, the orientation and continuity of adverse joint including trace length and spacing, <br />rock types and material strength parameters for individual lithologic units including uniaxial, <br />triaxial, and shear strength testing of intact rock as well as direct shear testing of sawed and <br />surface ground samples, and evaluation of all potential failure geometries including, at a minimum, <br />plane shear down the dip direction of a single joint set and wedge shear down the plunge bearing <br />of the intersection formed by multiple joint sets. <br />S. Lack of Specific Commitments <br />There are numerous places within the application submittals where the operator is vague or <br />makes unsubstantiated assumptions. For example, the application gives two possible sources far <br />the material to be used for the compacted soil liner. CC&V has indicated verbally that the <br />amended tails are to be used, but there is no documentation in the application to this effect. An <br />example of an unsubstantiated assumption is found in the section on water balance, where it is <br />assumed that porosity of the heaped ore will be 30 percent. Porosity of the ore is a critical factor <br />in calculating water balance in a valley fill heap leach, and the value Heads to be determined from <br />direct testing of the crushed and run of mine ore. <br />The Division recognizes that assumptions need to be made in design work, and are often <br />acceptable; however, we need as much as possible to receive commitments regarding design and <br />design criteria. The operator can remain flexible within the criteria through submittal of as-built <br />documentation which will describe and justify any variation from approved designs. <br />;f. Monitoring. Verification and Reoortina Program <br />In order to avoid misunderstanding, the applicant should submit a brief but comprehensive <br />description of a "Monitoring, Verification and Reporting Program." This program should clearly <br />state the purpose of the program. It should include consideration of all forms of monitoring; <br />geotechnical, hydrological, water quality, air quality, revegetation, etc. It should summarize the <br />monitoring facilities to be installed and observations to be performed, including a schedule or <br />frequency of monitoring. It should commit to the periodic reduction of the monitoring data and <br />the comparison with project design properties and performance standards. Appropriate reporting <br />frequencies should be proposed, with no less frequent than annual report submittals. Exhibit L, <br />"Reclamation Costs" should be amended to include bonding necessary to complete the monitoring <br />and verification program in the event of default or premature termination of the project. Finally, <br />the applicant's proposal should clearly state the applicant's commitment to have responsible <br />professionals in charge of site operations and the conduct of the monitoring program. <br />If you have additional questions or concerns please call. <br />