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May Day /Idaho Mine — Geotechnical Stability Exhibit Comments to September 9, 2011 <br />Response <br />Page 2 <br />September 28, 2011 <br />provide a written commitment to resolve this adequacy issue via the TR or AM process. The <br />revised text for this adequacy issue presented in the subject response letter shall be included in <br />the revised Geotechnical Stability Exhibit. <br />Adequacy Issue No. 6: <br />a. The applicant has committed to revising the second to last paragraph on page 8 to refer to <br />Attachment D -6, Figure D -2. However, they have not committed to addressing this <br />adequacy issue in a TR or AM. Please provide a written commitment to resolve this <br />adequacy issue via the TR or AM process. The revised text for this adequacy issue <br />presented in the subject response letter shall be included in the revised Geotechnical <br />Stability Exhibit. <br />b. The requested labeling of side slopes and horizontal scale for Section "A" have not been <br />included on the revised drawing (Attachment 3 /Attachment D -6, Figure D -2 (dated <br />9/7/2011). This part of the response is inadequate. <br />c. The last three sentences of this response are not entirely accurate. The proposed <br />augmentation pond appears to incorporate the embankment of the existing pond (west <br />side, south end). This embankment is vegetated with large shrubs and appears overly <br />steep. DRMS will require a stability analysis to demonstrate the existing embankment is <br />stable (as is) or require a new stable embankment be constructed in its place. The portions <br />of the proposed augmentation pond that are constructed and/or excavated into natural <br />ground and no fill is used will not require a stability analysis unless other earth moving <br />activities (e.g., road improvements) steepen the natural slope in the vicinity of the pond. <br />This part of the response is inadequate. <br />Adequacy Issue No. 7: <br />a. The applicant appears to use the engineering terms "stability" and "capacity" <br />interchangeably. These terms have different meanings: Capacity should be used when <br />referring to load capacity and abutment bearing capacity. Stability should be used when <br />referring to abutment susceptibility to scour and/or erosion, and the bridge's torsional <br />stability. <br />b. The first two bullets in this response are redundant. The first bullet should be deleted in <br />favor of the second, as it is more detailed. <br />c. The Applicant has proposed to resolve this adequacy issue in a follow -up Technical <br />Revision (TR) or Amendment (AM), to be submitted subsequent to the approval and <br />issuance of CN -01. All but the first of the 11 bulleted responses to this adequacy issue <br />presented in the subject response letter shall be included in the revised Geotechnical <br />Stability Exhibit (see Adequacy Issue comment 7b). <br />d. The last line of the response to this adequacy issue references a new Attachment 6.5.6, as <br />Attachment 6. The new Attachment 6.5.6 consists of two copies (one, half size) of a one- <br />page letter from William C. Birza, P.E., dated November 8, 2006; and an unlabeled <br />sketch of what appears to be a bridge cross - section. The letter only offers Mr. Birza's <br />opinion, no analyses. The sketch is not referenced in the letter. Without labels and <br />dimensions, the sketch is not useful. DRMS has not completed an assessment of the <br />bridge submittal. <br />Adequacy Issue No. 8: The applicant has committed to resolving this adequacy issue. <br />However, they have not committed to addressing this adequacy issue in a TR or AM. Please <br />c: \pegleg\my documents -2 \my documents \correspondence, minerals, 2011\may day cnl, 6, tac, <br />exh6.5,28sep 1 1 .docx <br />