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Letter: Response to adequacy review, Permit Application M-2008-010 4/25/2008 page 10 <br />two hundred (200) feet of the affected land, but his statement still, in <br />our opinion, meets the requirements of Rule 6.4.19 (b). Mr. Barton has <br />examined the structures listed in Exhibit S and has evaluated them and <br />determined that those structures will not be damaged by activities <br />occurring at the mining operation because there is little or no likelihood <br />of structural or other conditions in the soils, materials being mined, or <br />underlying material which would create damage based on the method <br />and areas of mining. If this is not believed by the Division to be an <br />"appropriate engineering evaluation" which meets the requirements of <br />the cited rules, please provide an example of what would be <br />considered to be "appropriate" and an explanation of why the signed <br />and sealed engineer's statement is not acceptable, so that we can <br />provide what is necessary. <br />To further amplify, there are no documented or observed geological <br />hazards on the site or in the vicinity to the site which have the potential <br />to affect any proposed impoundment, slope, embankment, highwall, or <br />waste pile within the affected area. Therefore, there are no geological <br />hazards that might be de-stabilized or exacerbated by mining <br />Although the Division is not requesting an engineering stability analysis <br />for proposed final reclaimed slopes, highwalls, waste piles, and <br />embankments, the following information is elaborated on: <br />a. There are no proposed "final reclaimed highwalls" for this project; <br />all highwalls will be reduced to a 3:1 or better slope. <br />b. A 3:1 slope is a commonly acceptable slope and considered to be <br />stable unless there are counter-indications, for both the Mancos <br />shale and alluvial materials found on the site and remaining as part <br />of the final reclamation. Observation of road cuts, trenching, <br />cutbanks, and other features in the vicinity of the Mud Creek Pit <br />show no indications that a 3:1 slope would not be stable. <br />c. There are no proposed "final reclaimed waste piles" for this project. <br />All acceptable wastes will be incorporated into the reduction of the <br />high walls as part of reclamation: <br />d. The only objects which might be defined as "final reclaimed <br />embankments" that are proposed as part of this project are items <br />such as rock check-dams and naturally-present materials which are <br />left in place and not mined. These have side slopes of 3:1 or better <br />and are incised, rather than constructed. Therefore, as with the <br />slopes (item b above), there is no reason to believe that any <br />potential for embankment failure exists. <br />e. Unless the Division believes otherwise, there are no geological <br />structures or constructed earthen facilities on this project; therefore <br />there are no failures possible, and no potential for off-site impacts. <br />Therefore, there is no need for a geotechnical and stability analysis. <br />Further elaboration of the analysis conducted to prepare Exhibit S: <br />