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to stabilize mine slopes that have been .subject to production blasting, and where final reclamation <br />blasting had not yet occurred. There are-no costs dedicated to this required reclamation blasting in the <br />cost estimates provided by the Applicant. An estimate of tliese costs must be provided, for DBMS review. <br />The estimate must consider the point in the mine plan where the greatest surface area of mine slope <br />would require reclamation blasting, which is not necessarily at the point gf Ji ll mine out of the pits. If the <br />Applicant wants DBMS to consider reclamation blasting completed concurrently with the mine pits <br />reaching the pit limits, then a plan for concurrent reclamation blasting that will be enforceable under the <br />terms of the permit must be provided. If the Applicant wants the DBMS to consider reclamation blasting <br />to be unnecessary. for portions of the pits to be bacVilled, then the language in AM-09 allowing <br />essentially total flexibility in the implementation gfpit backfilling must be rescinded, and reclamation <br />cost estimates to allow bonding for backfilling, at the point in the nine plan when those costs would be <br />maximized, must be provided. <br />CC&V Response: <br />With a few small exceptions, all mine slopes developed in the mining district have been stable, <br />with slope angles up to 60 degrees, and slope heights up to 1,500 feet (to date) and that is not <br />anticipated to change as a result of the MLE Project. DBMS is correct in stating that special <br />blasting and wall preparation are proposed by CC&V as part of final wall excavation, as specified <br />in Appendix 5, Volume IV of the Amendment No. 9 application. The special blasting for specific <br />areas of poor rock quality generally comprises creation of a triple bench configuration (with 105 <br />feet between catch benches), with the final face of each lift being formed using close-spaced, <br />lightly loaded holes, either pre-split or trim blasted, and the final face scaled to remove loose <br />material. Due to access and safety considerations, this special face excavation is and must be <br />conducted progressively as part of mine operations, whenever a production level reaches the final <br />wall location. In the event that production ceases prematurely, the final walls excavated to that <br />point will be complete and stable. Any other walls existing at such a time will be production <br />faces on the floor of the operating mine, no higher than a single lift (35 feet high), and located at <br />least one blast pattern away from the toe of the final slope excavated at that time. 'T'hese small <br />faces are also stable as mined and can be scaled as final operational activities while removing <br />remaining ore from any prematurely closed surface mine. In addition, CC&V phased bonding <br />approach will deliver full financial warranty for closure of the 110 million tons of ore to be <br />placed upon the Phase 5 VLF at the time of Phase 5 liner certification. Should mining be <br />discontinued prior to the proposed final mine configuration, the VLF closure activities will be <br />over- bonded and these funds could provide for additional costs that could be associated with <br />scaling a remaining highwall in the North Cresson or East Cresson surface mine, if somehow <br />needed but as noted above unanticipated. For these reasons, CC&V maintains that there will be <br />no uncovered reclamation cost associated with stabilizing these faces in the event of premature <br />closure, and thus there is no need for additional bonding associated with slope stabilization in the <br />financial warranty to be posted by CC&V. <br />DBMS Question to CC&V Adequacy Response (Jared Ebert): <br />General Plan (Project Description section 11.3): <br />A.) Topsoiling: According to their response, they have committed to endeavoring to salvage as much <br />topsoil as they can, and this varies throughout the site. They still want to keep the <br />minimum replacement depth at 6 inches. As long as they have committed to salvaging as <br />much topsoil as it available and they intend to spread it evenly, the minimum replacement <br />depth of 6 inches is acceptable. However, it is their responsibility to re-establish a <br />diverse and long-lasting vegetative cover over the mine site that correlates with the post <br />nine land use. They will not be released,kom their reclamation responsibilities if this is <br />not achieved. <br />CC&V Response: <br />Agreed.