2011-09-09_REVISION - M1981185 (43)

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Mr. Wallace H. Erickson Response to Fifth Adequacy September 9, 2011 Page 10 Adequacy Issue No. 6. Design specifications, certified by a licensed professional engineer, are required for all Environmental Protection Facilities under Rule 6.4.21(10), including the redundant containment measures required under Rule 6.4.21(7)(a). The Division has clarified that designs were required for the following structures: • Mill building DEN 97,599,531v1 9 -9 -11 reconnaissance to develop a detailed summary of the rock conditions at the highwall. o As necessary based upon preliminary rock mechanics field observations, obtain appropriate rock sample to perform laboratory analysis of rock mechanical properties. o Selected samples will be transported for laboratory testing including testing for rock mechanical properties, moisture content, dry density, strength, classification, grain -size distribution, and compaction tests. o Perform engineering and geologic evaluations to develop conclusions and recommendations regarding the following: • Stability of the highwall; and, • Design criteria for methods to stabilize or reclaim the highwall, as necessary. o Prepare a technical memorandum summarizing the results of the work described above. o Submit revised design plans for portal stabilization, including repair drawings and specifications, or revised reclamation plans and maps, as necessary, through the Technical Revision or Amendment process. o After obtaining DRMS approval through the Technical Revision or Amendment process, proceed with remainder of work plan. • Storage sheds, including Zircon or large shipping containers, in which designated chemicals are stored or utilized • Location of dewatering of tailings • Pipelines for tailings and recycled process water GREENBERG TRAURIG, LLP • ATTORNEYS AT LAW • WWW.GTLAW.COM