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<br />Memo to Christine Johnston <br />Mountain Coal T.R. 69 Adequacy <br />page 2 <br />each of these instances Mountain Coal has had to submit proposed <br />technical revisions to treat and repair the stability problems. In <br />some instances, such as the conveyor, repeated treatments have been <br />necessitated. As Mountain Coal has observed in every instance, <br />these remedial treatments have been expensive :• <br />Mountain Coal's T.R. 69 application contains a stability analysis <br />prepared by Envirocon, Inc., consultant to Mountain Coal. The <br />analysis applies standard methodology to evaluate the likelihood of <br />a rotational failure in the immediate vicinity of the fan bench and <br />the fan bench faceup. The analysis uses strength values previously <br />determined at the site. No reference is given to allow me to <br />determine where and when the samples were obtained or what <br />methodology was applied in determining their mechanical parameters. <br />None-the-less, the strength parameters chosen appear representative <br />for the materials encountered in the bore holes and modeled in the <br />analysis. That is to say, representative values for unsheared <br />samples of these earthen materials. The modeled bedrock <br />configuration suggests an excavated foundational benched pocket in <br />stable bedrock. Unfortunately none of these assumptions appear to <br />be appropriate for the chosen site. <br />As a portion of my review I examined our stereographic aerial <br />photography of Lone Pine Gulch. Specifically, I examined <br />photography obtained in 1980, 1982 and 1993. My examination <br />discerned topographic artifacts which I interpret to be indicative <br />of repeated, shallow and deep-seated slope failures (landsliding) <br />throughout the majority of the northeast facing slope of Lone Pine <br />Gulch. In the immediate vicinity of the proposed ventilation fan <br />facility the imagery suggests a large prehistoric landslide complex <br />has been the scene of more modern historic landsliding. The <br />coincidental bench and hollow landform in which Mountain Coal <br />proposes to place the ventilation fan and attendant facilities <br />appears to be the result of a moderately-sized modern rotational <br />landslide. The appearance of the landslide body suggest its <br />probably less than fifty years old. I have attached a sketch of <br />the aerial photo landslide landform boundaries. <br />Simply stated, the proposed site for the ventilation fan <br />installation appears unsuited for the proposed use. I suspect that <br />at the least the facility will be plagued by recurrent operational <br />problems as progressive "slope and foundational adjustments" occur. <br />Large fans and their gyroscopic high RPM electric motors do not <br />respond well to abrupt changes in attitude. Larger landslides or <br />rockfalls could render the fan and its portal and shaft inoperable, <br />representing a significant safety threat to mine manpower. <br />Finally, appropriate reclamation of the site, including elimination <br />of the fan bench highwall at a minimum, may be infeasible. <br />