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Page 9 of 10 <br />(2) On a site-specific basis, an Applicant shall be required to provide engineering stability analyses for proposed final <br />reclaimed slopes, high-walls, waste piles, embankments, and ore leach facilities. An Applicant may also be required <br />to provide engineering stability analyses for certain slope configurations as they will occur during operations, <br />including, but not limited to, embankments and ore leach facilities. Information for slope stability analyses may <br />include, but would not be limited to, slope angles and configurations, compaction and density, physical <br />characteristics of earthen materials, pore pressure information, slope height, post-placement use of site, and <br />information on structures or facilities that could be adversely affected by slope failure. <br />(3) Where there is the potential for off-site impacts due to failure of any geologic structure or constructed earthen <br />facility, which may be caused by mining or reclamation activities, the Applicant shall demonstrate through <br />appropriate geotechnical and stability analyses that off-site areas will be protected with appropriate factors of safety <br />incorporated into the analysis. The minimum acceptable safety factors will be subject to approval by the Office, on <br />a case-by-case basis, depending upon the degree of certainty of soil or rock strength determinations utilized in the <br />stability analysis, depending upon the consequences associated with a potential failure, and depending upon the <br />potential for seismic activity at each site. <br />(4) At sites where blasting is part of the proposed mining or reclamation plan, the Applicant shall demonstrate through <br />appropriate blasting, vibration, geotechnical, and structural engineering analyses, that off-site areas will not be <br />adversely affected by blasting. <br />Please address blasting program compliance as requested in comment for 6.4.4(1) <br />What is the monitoring/documentation program that has been implemented to monitor for stability issues <br />that may occur in the OSF and TSF dams during construction, operation and maintenance (phreatic surface <br />monitoring, permanent inclinometers, etc)? This monitoring/documentation protocol should be clearly <br />specified, and will be included as an enforceable condition of the permit when approved. <br />The introduction of the Geotechnical Stability Exhibit submitted with AM-06 states that the information <br />submitted is a preliminary overview, and that the design at this time is not considered final. Obviously the <br />long-term stability of the OSF and TSF features is a primary concern of the Division. While the preliminary <br />evaluations appear in order, DRMS does not review/approve "preliminary designs" and will therefore <br />require final design specification evaluation and approval before the site resumes mining and additional <br />material is placed in the existing TSF or OSF facilities. Please consolidate and provide the CPT and <br />laboratory data protocols and reporting referenced and used in the preliminary design modeling. Also, when <br />submitting the final design specifications and evaluations, complete dynamic loading analysis for the TSF <br />features will be required. These final design specifications and stability evaluations may be subject to third <br />party review as outlined in Rule 7.4.3. <br />Rule 7.3 Environmental Protection Facilities - Design and Construction Requirements <br />and Rule 7.4 - Facility Certification and Inspection <br />Climax should review these sections of the rule carefully to determine if ongoing and planned construction activities <br />(mill facility, new pumping facilities, EPF's etc.) and the associated required submittals and certifications are being <br />carried out in compliance with these requirements. <br />Additional Information Required: <br />Any letters from other commenting agencies/entities received by the Division to date not already submitted to Climax have <br />been included with this correspondence for you to review. <br />This concludes the Division's preliminary adequacy review of this application. This letter shall not be construed to mean <br />that there are no other technical deficiencies in your application. Other issues may arise as additional information is <br />supplied. Please remember that the decision date for this amendment application is January 21, 2011. As previously <br />mentioned, if you are unable to provide satisfactory responses to any inadequacies prior to this date, it will be your <br />responsibility to request an extension of time to allow for continued review of this application. If there are still unresolved