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Corey Heaps <br />McClane Canyon Mining, LLC <br />February 15, 20I1 <br />Page 14 <br />b. The first paragraph refers to Appendix A, which was not included in the report <br />submitted. Please refer to the similar comment in the Table of Contents section, above. <br />c. In subsection 4.1 — Index Properties, the discussion appears to be identical to that <br />contained in the 2007 report. Please revise the title of this subsection to be "2007 <br />Laboratory Testing ". <br />d. Subsection 4.2 — 2010 Laboratory Testing states that a Standard Proctor test was <br />conducted on a sample of air jigged coal. Please provide the results of the Standard <br />Proctor Test. <br />e. Subsection 4.2 indicates that CU and UU triaxial test results are presented in Appendix <br />C. They are actually provided in Appendix B. Please correct the reference. <br />62. Section 5.0 — Stabilfty Evaluations <br />a. Printouts of stability evaluations have not been provided (TOC indicated they should be <br />found in Appendix Q. Please provide printouts for the Division's review. <br />b. Table 3 gives effective stress shear strength parameters of coal waste from CU triaxial <br />testing (0 = 27.3 c'= 345psf), but these values are not carried over to Table 4, which <br />shows 0 = 30 °, c'= 0 psf. Please review the parameters, revising as necessary, and <br />ensure that the intended parameters were utilized in the stability evaluations. <br />C. The text in Section 5.3 — Stability Evaluation Results, along with Table 5, has been <br />copied verbatim from the 2007 study. The Division believes this is an error. Please <br />review and revise as necessary. <br />d. Subsection 5.4.2 -This paragraph refers to the unit weight and internal friction angle of <br />coal waste, but does not mention any sensitivity related to cohesion of the coal waste. <br />Please review and revise or clarify if necessary. <br />63. Section 6.0 — Conclusions and Recommendations <br />a. The last sentence of the first paragraph gives a critical factor of safety of 1.7 for <br />effective stress analyses. Using a linear relationship, as described in the preceding <br />paragraph, the Division believes that FS = 1.6 for the measured 0 of 27.3° may be more <br />accurate. Please review the calculations, and revise if necessary. <br />Rule 2.05.4 Reclamation Plan. <br />64. MCM will have 31,000 cubic yards of topsoil salvaged and stored in a well protected area <br />within the permit boundary. On page 2.05 -26, a little over halfway down the page it says that <br />the topsoil stockpile will have 2.5 horizontal to 1 vertical side slope utilization. In Figure 2.2 -2, <br />in cross section B -B' it references a 2H: I V. Please amend the narrative to reflect Figure 2.2 -2. <br />