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-- , f V <br />Coarse Fractio <br />Before Test - Saturated <br />Wet Density 113.9 lb/ft3 (1.5 ton/yd3) <br />Moisture Content 25.3% <br />Percent Saturation Level 81.7% <br />Dry Density 90.9 lb/ft3 (1.2 ton/yd3) <br />n Consolidation <br />After Test - Under-saturated <br />118.5 lb/ft3 (1.6 ton/yd3) <br />25.5% <br />under-saturated <br />94.5 lb/ft3 (1.3 ton/yd 3) <br />Slimes Fraction Consolidation <br />Before Test - Saturated After Test - Under-saturated <br />Wet Density 110.7 lb/ft3 (1.5 ton/yd3) 121.4 lb/ft (1.6 ton/yd3) <br />Moisture Content 43.3% 30.4% <br />Percent Saturation Level 100.5% under-saturated <br />Dry Density 77.2 lb/ft3 (1.0 ton/yd) 93.1 lb/ft (1.3 ton/yd) <br />Important Impoundment Stability Measure - The consolidation data above provide for a standard of comparison <br />for evaluating consolidation during operations, utilizing a core sampling procedure that has already been described <br />earlier in Exhibit C. Core samples shall be determined under-saturated when testing reports Moisture Content data <br />less than the Before Test - Saturated conditions in the above table. This condition demonstrates the impoundment is <br />consolidating and that saturated, phreatic zones are being mitigated through proper dewatering and drying. <br />Additionally, we have elected to incorporate standpipe piezometers into the design as a simple and effective means <br />of measuring the saturated, phreatic surface level. Standing water will be measured in these standpipes if saturated <br />zones exist and an embankment profile can be mapped. See revised Exhibit C for the standpipe piezometer testing <br />method. <br />Relating to this information, the DRMS asked a question on November 8`s: "Where did you source the Unit Weight <br />Soil Data in the Synteen stability analysis?" Soil density is based largely on three variables: the mineral content, <br />water content, and the effect of applied energy. A single, definitive soil density value is not a firm number and must <br />be considered in a particular environment. To provide for a conservative design, Synteen utilized the <br />TRI/Environmental data reported in the Proctor Density curves. The Proctor Curves report a maximum dry density <br />(7d,y max) having an optimum moisture content (%MC). Maximum wet density, a more pertinent value, is calculated: <br />ywet max ° (ydry max) (%MC), <br />for coarse fraction ywat max = (104.3 pef) (1.114) = 116.0 pcf, max. wet density. <br />for slimes fraction ywet max = (109.1 pcf) (1.161) = 126.5 pcf, max. wet density. <br />This approach uses the worst case, heaviest wet densities to provide for the most conservative design. <br />DRMS Statement in Review Item #2: <br />"Analysis of impoundment with unsaturated slimes yields a safetyfactor of 1.33 under static conditions and 1.03 <br />under pseudostatic conditions. The pseudostatic coefficient input was set to the peak ground acceleration for an <br />earthquake with two percent in fifty years return period at Hukill Gulch, as obtained from <br />earthquake. usgs.gov/hazards. These safety factors are unacceptably low, and complete dewatering of tailing is <br />unlikely. " <br />Venture Resources Response to Review Item #2: <br />Venture Resources and Synteen Technical Fabrics have considered the above requirement and have used a value of <br />0.12 for the peak ground acceleration of an earthquake with 2% in a 50 year return period in the seismic stability <br />analyses. Please seethe USGS Peak Ground Acceleration Map, 2% in 50 year return period data attached as anew <br />appendix to the revised Exhibit C. Refer to the new design table of factors of safety contained in Item #I above. <br />Our professional knowledge and experience (Venture Resources' staff has two Certified Professional Engineers and a <br />Certified Professional Geologist) tells us that the tailings will dewater, dry and consolidate and that the impoundment <br />stability only increases over the long term. Offhand, unsubstantiated comments such as "... complete dewatering of <br />Page 3 of 5