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Mr. Laroche and Mr. Tuttle <br />Page 4 <br />November 28, 2011 <br />6.5 Geotechnical Stability Exhibit <br />9. Pursuant to Rule 6.5(3), the Applicant shall demonstrate that off -site areas will be <br />protected with appropriate factors of safety (FOS) incorporated into the analysis. The <br />minimum acceptable safety factors will be subject to approval by the Division, on a case <br />by -case basis. The assumed minimum FOS of 1.01 is unacceptable. Standard <br />engineering practice /standard of care uses a FOS between 1.25 and 2.0 depending on the <br />certainty of the strength data and the consequences of failure. Furthermore, the analysis <br />does not provide sufficient discussion of the zone of influence or gradient of the phreatic <br />surface necessary to evaluate the groundwater level assumed in the SlopeW model. <br />a. The Division will accept a FOS = 1.25 for fences, but will require a FOS = 1.5 for <br />buildings. Please provide the appropriate revised slope stability analyses. <br />b. The surcharge load resulting from the topsoil stockpiles on the edge of the pit <br />should be included in the stability analyses. <br />c. Discuss potential offsite consequences of a diversion channel failure with respect <br />to: <br />i. Stormwater retention onsite and the SEO's 72 -hour release requirement, <br />ii. Water quality at the discharge (i.e., if the channel were to fail and flood <br />the pit, would the settling basin be adequate to control suspended solids ?). <br />If either items i or ii above pose an offsite consequence, the Applicant shall <br />provide a stability analysis demonstrating an FOS = 1.25 against channel failure <br />(i.e. pit -side bank sloughing into the pit) with the channel at the 100 -year design <br />capacity. <br />d. Provide phreatic surface discussion for that surface used in the analyses. <br />SECTION V, EXHIBIT E — AMENDMENT 4 RECLAMATION PLAN FOR PHASE 1 <br />10. Page 2, Materials Handling — General slope from northwest to southeast of 4 to 5 feet <br />(across approximately 2600 horizontal feet) results in a final slope of 0.15 to 0.2 percent. <br />This is an order of magnitude less than the one percent slope proposed for Phase 7 <br />reclamation. <br />a. Please provide some discussion comparing the pre -mine slopes with the proposed <br />post -mine slopes and why the difference from the one percent slope proposed for <br />Phase 7 reclamation. <br />b. Also address the slope with respect to promoting drainage to prevent the basal rot <br />of the smaller cottonwood trees. <br />11. Page 3, Topsoiling and Growth Media — If it is unsafe to get heavy equipment on the <br />Phase 1 sediment ponds, how is the topsoil to be distributed? <br />12. ExhibitF-1A — Please show: <br />a. Proposed final reclamation contours, <br />b. Proposed final reclamation channels (between sediment basins). <br />