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Adequacy Letter - TR 65 <br />September 17, 1993 <br />Page 5 <br />manner. Mr. Pendleton has the following adequacy concerns <br />regarding the report: <br />1. The slope stability analyses for pond MB-2R should be revised <br />appropriately when the design has been finalized. <br />2. Particular emphasis should be placed, in the slope stability <br />analyses, upon the possibility of liner leakage or <br />deterioration contribution to the possible failure of the <br />inner slopes of the pond. If appropriate, an inspection <br />program should be required to insure the integrity of the <br />synthetic liner. <br />3. Many of BBC&M's assumptions and design recommendations assume <br />dry conditions in the foundational horizons of the stack tube, <br />reclaim tunnel, dozer basis and pond MB-2R. If sufficient <br />groundwater monitoring wells are not already in place to <br />observe the alluvial groundwater level in the area under <br />consideration, additional wells should be installed and <br />monitored. <br />ROADS <br />1. Revised page 2.05-22 should state that the new access roads <br />and light-use roads are a graveled surface. MCC should submit <br />this revised page. (Rules 4.03.2(5) and 4,03.3(5)). <br />2. If cut slopes are required for construction of the access <br />roads, they should not be steeper than 1.5H:1V <br />(4.03.3(c)(i)). <br />3. Will the construction of new access roads and light use roads <br />require any removal of topsoil? If so, please detail in what <br />areas topsoil will be removed and where the topsoil will be <br />stored? MCC should update the table on revised page 2.05-45. <br />4. When will MCC seed the pond embankments, road cuts, etc.? The <br />Division would recommend that seeding be done this fall, <br />weather permitting. <br />5. The Division disagrees with the statement made on revised page <br />2.05-22, which states that "Existing Forest Service roads and <br />roads constructed during exploratory drilling provide access <br />to monitoring stations not accessible from haul or access <br />roads and were not constructed nor maintained as light-use <br />roads". Pursuant to Rules 1.04.111(c), 2.05.3(3)(c), and <br />4.03.3, MCC's use of these roads constitutes a light-use road. <br />However, this issue will be resolved under the recently issued <br />notice of violation (C-93-114). <br />