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n .`_ <br /> <br />materials in order to make further evaluations of geochemical <br />characteristics. It is imperative that the Division emphasize to <br />the applicant that if further evaluations demonstrate that the <br />Cresson Pit materials are not acceptable for underdrain <br />construction, the operator would then be compelled to remove any <br />underdrain already in place, and replace it with acceptable <br />materials. The Division could accept underdrain fill from alluvial <br />or colluvial borrow sources with minimal geochemical evaluation. <br />Such materials would have to be shown to be durable and free- <br />draining. The following stipulation should be placed on permit <br />approval: <br />ALL UNDERDRAIN FILL MATERIALS MUST BE DURABLE AND CHEMICALLY <br />INERT, AND MUST MEET THE GRADATION DEFINED IN THE TECHNICAL <br />SPECIFICATIONS. IF ANY UNDERDRAIN FILL MATERIALS THAT HAVE <br />BEEN PLACED ARE SHOWN TO BE ACID OR TOXIN GENERATORS BY THE <br />ON-GOING OR FUTURE GEOCHEMICAL EVALUATIONS, SUCH MATERIALS <br />MUST BE COMPLETELY REMOVED, PROPERLY DISPOSED OF, AND REPLACED <br />WITH ACCEPTABLE FILL. <br />Blast Vibration Monitoring <br />I have reviewed the agreement between Citizens For Victor! (CFV) <br />and the applicant, and have no problem with these additional blast <br />vibration monitoring procedures being included in the Reclamation <br />Permit. As an administrative matter, you can either incorporate <br />the document into the permit by reference, or enumerate each item <br />as a separate commitment or stipulation. The Division should not <br />change the language in the CFV agreement, primarily because it <br />would serve no useful purpose to do so, and because we were not <br />involved in the process by which the agreement was reached, It <br />should be noted that specification of a maximum peak particle <br />velocity, such as 0.5 inches per second, while a common and usually <br />effective practice, does not take into consideration the possibly <br />more significant damage criterion related to the frequency <br />component of the blasting vibration and the resonant frequency of <br />the structure being excited. For this reason, I think CFV <br />agreement number 6 is an excellent inclusion into the Reclamation <br />Permit. <br />Operating and Reclaimed Slope Configurations of Waste Dump and Ore <br />Heap Fills <br />In the most recent version of Volume I - Amendment 6, it remains <br />unclear what slope configurations will be employed for the large <br />fills at the site. It is also unclear what type of reclamation <br />will be employed proposed slopes. There is mention within the <br />pages of Volume I of slopes that will remain at the angle of <br />repose, and slopes that will range from 2:1 to 2.5:1. There is <br />mention of plating slopes with oxidized rock for purposes of <br />reclamation, and of slope reduction "where revegetation is <br />planned". The Division needs to have the vagaries regarding slope <br />configuration and reclamation re-worked into a specific and <br />enforceable format. Without specification, there will be no clear <br />