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strength. The Operation and Monitoring (O &M) Plan in TR -22 contains a discussion of various <br />considerations which require attention during construction of the OSF in order to achieve the <br />best performance of the facility. For example, special attention will be required in winter to <br />reduce the risk of developing ice lenses in the OSF. In the event ice lenses do form, Golder <br />included a "worst- case" evaluation in the supplemental stability analysis to quantify the impact <br />of ice lenses on OSF stability. Other topics discussed in the O &M plan include water <br />management practices, construction quality control, OSF construction staging recommendations, <br />and monitoring requirements. <br />The risks to existing infrastructure depend on the scale of potential slope movements and the <br />run -out distance of those movements. The CRSP analysis included in the Design Report is <br />intended to quantify the potential run -out distance of individual rocks, and is also applicable for <br />estimating the run -out distance of rocks released by small sumps of material. The stability <br />analysis indicates that large scale failures should not occur, and therefore run -out analysis was <br />not performed for these types of failures. <br />In a separate request, DRMS asked for information regarding the stability of reclamation soil <br />stockpiles near McNulty Gulch. Please refer to Figure AM- 06 -F -02 of the 2010 Amendment 06 <br />Application that shows soil stockpile locations. The locations of all soil stockpiles in McNulty <br />Gulch are either located along flat areas /ridges or will be buttressed by OSF material such that <br />there is little potential for slope failure. <br />Climax appreciates the Division's consideration of these responses. Please feel free to contact <br />me should you have any remaining questions or comments. <br />Sincerely, <br />Raymond Lazuk <br />Environmental Manager <br />Attachments: <br />Attachment 1 — August 13, 2012 Golder Supplemental Geotechnical Stability Analysis <br />Attachment 2 — Section E -E' and Section C -C' of Limit Equilibrium Analyses to Support <br />Figure 13 of Attachment 1 <br />8 <br />