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13. The operator intends to use explosives for mining development. Please provide a description and <br />location of how the explosives will be stored. In addition, please further explain the MSHA <br />requirement for the storage and use of explosives. <br />14. Please provide a description and location of all temporary waste piles to be stored on site. Please <br />provide an estimated volume of all temporary waste piles that will be stored on site. <br />15. The operator states that future hanging wall development may require a lift or two (20'-30'h) of waste <br />placement above the current lower staging area. Please further describe this waste placement, locate <br />the azea on a map and provide across-section that provides further detail. In addition, the operator <br />will need to demonstrate that such placement in this location is stable, and coincides with the <br />reclarrtation plan. <br />16. Please clarify if Road 2281eading to the Lilly Mines is a county road or a USFS road. There is <br />conflicting information in the application as to the owner of the road. If it is jointly or partially <br />ovmed, please specify the location where it changes from a county road to a USFS road. <br />17. In a letter from the USFS dated March 6, 2006 addressed to your attention, the USFS states in part, <br />"...this system road has been used for commercial haul purposes, as well as for ingress/egress to <br />the Lilly Mines for quite some time. It is also appazent to me, through inspections for the road <br />conducted by members of my staff, that unauthorized maintenance and in some cases <br />reconstruction (road widening) activities aze, and have been performed on this facility without <br />an approved written authorization..." <br />Please be aware that any widening or modifications to an existing road may be considered a part of <br />the affected land. The defmition of "affected land" under Rule 1.1(3} includes road's which were <br />constructed or substantially upgraded to support the mining operation. Based on the USFS letter, it <br />appears that the road was significantly modified by the operator and will need to be included in the <br />permit azea. If this is the case, then the permit application will need to be amended to include the <br />road boundaries, and all review periods and publication will need to begin anew as required by Rules <br />1.6.6 and 1.8. <br />If the applicant plans to upgrade, modify or relocate Road 228 as a result of the mining operation, <br />Rule 6.3.3(g) requires the applicant to specify the existing or proposed roads that will be used for the <br />mining operation. Any improvements necessary on existing roads and the specifications to be used in <br />the construction of the new roads need to be described in the permit and included as part of the <br />permitted acreage. The applicant will also need to address reclamation of any new or improved roads <br />constructed on site and included in the reclamation cost estimate. <br />18. Road 228 is a public road that runs though the permit area. Please explain how the road will be <br />maintained for public access during the mining operation. <br />19. The operator proposes to relocate Road 228 along the west end of the permit boundary. In order for <br />the Division to approve the location of the new road, the operator must provide the following; <br />o A notarized letter from the owner of the road (County or USFS) that approves for the road to <br />be relocated as proposed by the operator. <br />o A commitment from the operator that existing road 228 will not be mined through until the <br />relocated road is approved in writing by the owner of the road. <br />o Designs for the road, including dimensions, grade, construction methods, drainage features <br />and a cost estimate to construct the road as per the design. Such design will need to include a <br />cross section. <br />