Forestalling Sudden and Unexpected Mining Disasters.

MSHA DIRECTOR JOE MAIN SAID IT: "WE'RE GOING TO SCOUR THE EARTH TO DETERMINE WHAT HAPPENED ...

AND WE'RE GOING TO LEAVE NO STONE UNTURNED !" Big Branch coal mine inquiry, April 2010.

BUT

BY "TURNING OVER SOME STONES" AT THE KENNECOTT EAGLE OPERATION

WE CAN PREVENT A "SUDDEN AND UNEXPECTED" DISASTER.

THIS STATEMENT IS BASED ON CORRECTING THE ORIGINAL 2006 APPLICATION FOR PERMITS,

AND THE PERMITS.

November 2014

JACK PARKER AND ASSOCIATES, INC. ROCK MECHANICS • MINING • GEOLOGY

PO Box 255, South Range MI 49963

Tel: 906-482-0099

OBSERVATION • MEASUREMENT • ANALYSIS • DESIGN

These photographs were provided, through FOIA, to illustrate the condition of the rocks

in one of the diamond-drill holes in the crown pillar.

Fifty feet of core from HOLE EA 67.

You may express your own opinion.

1 THE KENNECOTT EAGLE PROJECT APPLICATION FOR PERMITS TO MINE IS REPLETE WITH ERRORS AND OMISSIONS; BUT, MOST SIGNIFICANTLY, WHEN A VERY FEW OF THE ERRORS ARE CORRECTED THE KEMC CONCLUSIONS ARE REVERSED AND THE MINE AND THE CROWN

PILLAR ARE PREDICTED TO BE

UNSTABLE.

Jack Parker*

INTRODUCTION. From “Day One” I have had concerns about the many errors and omissions in the Kennecott Eagle project application (Figure 1). Health and safety, that's what it's all about.

Figure 1. This was a personal letter from one mining engineer to another, not financially involved but sensing dire consequences, in the year 2006. There was no response, and that in itself aroused curiosity, if not suspicions.

………………………………………

* Jack Parker is a semi-retired mining engineer/geologist – BS Mining Engineering, BS Geological Engineering and MS Geology at Michigan Tech in the 1950s. He has worked in and around mines, here and abroad, since 1946. Since 1971 he has been “self employed,” helping mine operators to resolve problems in mine design and operation, specializing in practical rock mechanics – which he defines as “an understanding of the properties and behavior of rocks and rock structures – and what to do about it.” The knowledge comes from experience in more than 500 underground mines. He has written numerous technical papers concerning the practical approach (First go look at it!) and has presented many seminars to miners and engineers. See attached resume. He dropped the title “consultant” when an early client said that it was condescending. It is.

2 Note that there was something wrong with the application, even in June 2006. But it didn't seem to bother anyone - not Rio Tinto, Kennecott, Golder Associates, not MDEQ/MDNR - the Regulating Agency, and not even the protesting National Wildlife Federation and their team of lawyers and experts. I was told, several times, “Forget it. It's a done deal." But, as Yogi said: "It ain't over til it's over!" For a couple of mining engineers, facts in hand, the situation resembled a bad dream. Marcia Bjornrud, PhD, at Lawrence University (Appleton, WI), studied the data independently and more stringently as a structural geologist and came up with similar findings. In the past eight years I have tried several times to show the many errors and omissions in the application – but have bogged down in details. The reports begin to resemble encyclopedias, full of facts perhaps, but nobody reads encyclopedias from beginning to end. This time I confine my observations to the most significant errors – those concerning health and safety, primarily the stability of the mine and the crown pillar in particular. The crown pillar is the rock above the mine. Instead of beginning with the basics, such as the strength of the various rock types, and progressing through all the steps in mine design, I begin with the conclusions, given in red ink on page one – to get your attention. Then come brief discussions of the factors which Kennecott/Golder (K/G) presented to show how they arrived at their conclusion that the mine would be stable. Then I show how obviously they departed from reality, and how their conclusions must now be reversed. Discussion of just two of their design approaches should suffice to convince the reader that the K/G conclusions are incorrect and dangerous, but I will include a few others for good measure. The reader may ask, “If the mine design is so incredibly bad why hasn’t it been corrected?” I speculate that no knowledgeable persons have studied it (except Sainsbury) and those who are not conversant with mine design must have thought that mining giants such as Kennecott and Golder Associates and Rio Tinto could be trusted to do good work. If so – they are sadly mistaken. Politics and theoretical considerations can be deferred, but structural stability must be addressed immediately. It is indeed a matter of life and death. To ignore this warning – not emotional and not political but entirely technical – is to share the consequences – the blame. On this Kennecott project I was originally hired by NWF (National Wildlife Federation) in April 2006, to help with technical evaluation, but the funds ran out and for the last seven years I have continued to work on the project unpaid – but also independent! THE APPROACH TO MINE DESIGN. Kennecott, through their consulting experts Golder Associates, chose to employ a “computer modeling” approach, whereby numbers are plugged into computer programs and formulas to arrive at designs. Neither of MDEQ’s hired experts, David Sainsbury and Wilson Blake, approved the approach. Because the programs and the input to them are based on absolutely invalid assumptions, I too disapprove, vehemently. UCS – Unconfined Compressive Strength of the rock is a prime example. All of the calculations and the predictions depend on it, yet Kennecott began their program by using an indirect and unacceptable method to measure it – the Point-Load test.

3 Even when Kennecott, or other operators, use “acceptable” methods to measure UCS I hold their results at arm’s length – because they are simply NOT representative of the rock mass or the conditions encountered underground. The rocks don’t lie but the numbers do. A typical 4” length of 2” diameter diamond-drill core is said to represent the properties of the rock mass in which a structure is to be formed – but in all steps of sample selection and testing the results are skewed because one begins by taking the best specimen in sight and by ignoring all the defective pieces and structures on which the real mine is likely to fail. Similarly if a specimen falls apart “prematurely” in a test the result is thrown out. In theoretical circles that dilemma is handled by applying an arbitrary “safety factor,” reducing the measured strength by 50% perhaps, and in so doing reducing the process to guesswork. I would expect those who make a living this way to defend it vigorously, but not to change it. For some purposes the UCS tests can be useful, as, for example, when comparing wet strength to dry strength – because that particular test should lead you to modify your mining techniques. K/G failed to consider that point. RQD – Rock Quality Designation. This system was introduced by a Professor Don Deere half a century ago to make numbers somewhat more acceptable in core description. K/G misapplies the system. Instead of using it to “red flag” sections of poor core which would indicate potential instability – the K/G approach actually hides them. By definition the RQD is the percentage of a sample of core which arrives at surface in lengths greater than two core diameters. Example: If 10” of a 2” core 4 ft. long arrives in pieces shorter than 4” – then the RQD will be 38/48 = 80%, commonly referred to as 80. Shortcomings are recognized. For example, the core is not truly representative. The cross-sectional area of a 2” core is about 3 sq. in. and it is meant to represent an area say 100 ft. square, i.e 1,440,000 sq. in., that is, 1 in 480,000! Go look at a quarry face to help you understand the insignificance of that little sample. Another example is that much depends on the orientations of the core and the fractures. If they are parallel the core may encounter no fractures, for an RQD of 100, but if the core is vertical and bedding planes are horizontal, for example, then the RQD could be much lower – in the same rock mass. Keep that in mind and you’ll be a step ahead of most of the experts who just look at the numbers. In their paper Deere and Deere specified that the RQD should be assessed as soon as the core comes up the hole. Kennecott specifies that the core should be boxed and hauled to a lab for assessment. Deere and Deere stressed the importance of “red flagging” sections of poor core because they threaten stability of the structure. Kennecott hides the poor core, by diluting it in a long sample. For example, 18” of poor core in Kennecott’s 10 ft. sample would earn an RQD of 102/120 = 85, whereas in Deere’s recommended 5 ft. sample the same 18” of poor core would earn an RQD of 42/60 = 70, a much lower value. Kennecott intentionally skews the data in their favor. RQDs do have some value. An RQD of 95 would be encouraging, for example (but with reservations), and an RQD of, say, 22 would be instantly discouraging, as far as structural stability is concerned. RMR – Rock Mass Rating – is a system developed by industry and academia to improve on RQD, by applying modifiers observable in real rock masses (as opposed to small, selected intact specimens).

4 K/G again got it wrong in several ways, intentionally or otherwise, with the end result that plans and predictions of stability are also incorrect. Deplorably so. This is their formula: RMR = A1 + A2 + A3 + A4 + A5. A1 is the lab-measured UCS of rock samples. We have already discredited the sampling and testing procedures with their unrealistically high results, which do NOT represent the rock mass. Still, in an exhibition of blind folly, K/G accepts them and points are awarded as follows: 4 points for the lowest strength, 15 for the highest and 7 or 12 for intermediate strengths. I do not consider that procedure scientific. A2 is based on the RQDs, carrying with them the same limitations. For an RQD of 25 or lower only 3 points are allowed. RQDs between 40 and 100 are divided by 5 – so an RQD of 70 would get 14 points. This procedure too is arbitrary, not scientific. A3 is based on the spacing of natural discontinuities in the core, so it too is related to RQD. If breaks are 10 ft apart, as in massive rock, 30 points are awarded. (This would be true even if the core had managed to sneak between two major parallel fractures.) If the breaks are close together, say 2” apart, the core still gets 5 points – although to my way of thinking it adds nothing to strength of the structure. It adds dead load. A4 depends on the condition of the breaks – are they filled or open? Altered? Rough? Smooth? Up to 25 points can be assigned – based on some individual’s opinion and sense of job security. A5 is, in the present context, very significant, because all of the RMRs assigned in the project are 10 points too high. A5 relates to the degree of wetness or dryness in the breaks. Elsewhere in the application, notably the Subsidence report, the rocks are considered to be water-saturated, but in the RMR modification they are said to be dry. Points to be awarded varied initially from 0 to 15, depending on dryness, until Sainsbury pointed out the 15 could bring the total higher than 100 – so K/G reduced the A5 maximum to 10 points. CONSIDERING THAT THE ROCKS ARE WET, NOT DRY AS ASSUMED, ALL OF THE RMRs ARE TEN POINTS TOO HIGH. Initially, when the maximum was 15 points, the RMRs were 15 points too high. It is not clear whether the correction should therefore be 10 or 15. EITHER WAY – THE CORRECTED RMRs, APPLIED TO K/G METHODOLOGY, PREDICT THAT THE MINE AND THE CROWN PILLAR WILL BE UNSTABLE. You may need to read that sentence again. You’d better believe it. MANIPULATING THE RMRs. ALL OF THE DESIGN WORK AND THE PREDICTIONS OF STABILITY, AND THE OUTSIDE REVIEWS, DEPEND ON THE COLORED DRAWINGS, PLANS AND SECTIONS OF RMR FURNISHED BY K/G. ALL ARE DEFECTIVE, SKEWED TO FAVOR THE SUCCESS OF THE APPLICATION. DRAWINGS COMPARING RQDs AND RMRs. Figure 2 is an example. Tabulated values were transferred to drawings at the location of the drill holes. Contours (lines of equal value) were then interpolated between holes. Then the areas between contours were color-coded, from red to show poorest conditions to green and blue showing the best. Note immediately that the contours around the red holes are close together – “bull’s-eyes” – implying that their influence is local, not widespread. The contours between blue/green holes are far apart, implying that the good conditions are widespread. That, of course, skews the information toward favorable conditions.

5

Figure 2. Drawings comparing RQDs and RMRs on a horizontal slice through the ore body, roughly in the middle of the ore body.

6 Apart from drilling additional holes there is no way to predict what lies between holes, whether the change from red to blue is abrupt or gradual, or where the change takes place. K/G opts for optimistic interpolation, more guesswork. MOST GRIEVOUS IS THE SYSTEMATIC AND UNFORGIVABLE OMISSION OF LOW-RMR DATA FROM THE DRAWINGS AND THE CONCLUSIONS DEPENDENT ON THEM. THEY HID THE BAD NEWS. Figure 2 illustrates the point. It represents conditions on a horizontal slice through the ore body, roughly in the middle of the ore body (see lower sketch). At top left in the upper drawing, RQDs, is a large ominous patch of reds and oranges. This is appropriate, because the cores there are broken and the RQDs are low. Look again at the frontispiece. Does that look like “solid rock”? But now look at the middle drawing, RMRs. That ominous red/orange patch does not show up! Hey! We, like everybody else, had assumed that we were being fed sound engineering information; but now we smell a rat. Existence of the rat was confirmed when we obtained a tabulation of RQDs and RMRs for “our” eight holes. THE LOW RQD VALUES WERE ON RECORD, BUT CORRESPONDING RMRs WERE MISSING. THOSE LENGTHS OF POOR CORE HAD BEEN OMITTED AS IF THEY DID NOT EXIST. MINE PLANNERS, REGULATORS AND OUTSIDE REVIEWERS ALIKE DID NOT NOTICE THE DECEPTION. It is subtle and clever, although not especially smart. SO SAFETY WAS INTENTIONALLY COMPROMISED. We checked all eight of “our” cores and found the same “mistake” in all of them. In Hole 64, one of the 26 chosen by K/G to represent the rocks in and around the crown pillar, 87 feet of poor core was omitted from the RMRs. Curious to see how much the missing lengths had affected the apparent RMRs on the tables and the drawings, I took the RQD/RMR records of the upper part of “our” eight holes – assigned low or zero RMRs for the low-RQD core – then recalculated the weighted RMR averages for the upper 100 ft., 200ft. and 300 ft. of core in each, as if evaluating the three proposed thicknesses of crown pillar. I WILL COME BACK TO THE BUSINESS OF “WEIGHTING IN THE AVERAGES.” The results appear on page 7 (Figure 3). Note that the highest RMR number in and around the crown pillar is 62.5. There are no 70s, 80s or 90s. All are sub-standard. And that was reported in February 2008. If I had looked into the RMR dry-rock issue AT THAT TIME THE NUMBERS WOULD HAVE BEEN 10 POINTS LOWER THAN THESE! Maybe 15 points lower. While I will never endorse the K/G methods, I conclude that – using their “methodology” and their numerical input, corrected for obvious “errors” – the outcome has to be that the structure, as planned, will be UNSTABLE. After his relatively short study the MDEQ’s #1 mining expert, David Sainsbury, stated that the conclusions in the application were not considered to be defensible, which means that they could not be supported by fact. We are in agreement. Their other expert, Wilson Blake, opined that he could not explain the omission of critical data – that it was not a normal procedure. He reviewed only a small part of the application; therefore, the final statement in both of his reports – a recommendation that the permits be approved – was unwarranted and should be questioned.

7

Figure 3. A tabulation: Crown pillar eight holes RMRs revisited Feb 2008.

HOLE NUMBER THICKNESS AVERAGED WEIGHTED AVERAGE RMR 55 100FT 53 200 57.6 300 62.5 60 100 27.5 200 44 286 49.7 bottom of hole 62 100 3 200 38 300 28 … there is a 111ft gap in RMR data. Maybe 41 if I assign a low RMR to part of it. 64 --- 0 No RMR assigned to upper 126ft! 200 46.7 300 55 67 100 36 upper 41 ft had no RMR given. (Frontispiece photos) 200 45 300 52 69 100 40 no RMR for upper 40 ft 200 56 300 57 99 100 52 no RMR for upper 57 ft 200 55 300 56 101 100 28 no RMR for upper 56 ft 200 49 300 53 I used the KEMC RMRs. Assigned RMR of zero where RQDs were too low. Calculated weighted average RMRs for the three proposed thicknesses of crown pillar. If I had subtracted the 10 points, for wet conditions, from the KEMC RMRs the new weighted averages would be even lower than shown. RMR equivalent descriptions: 90-100 very good; 70-90 good; 50-70 fair; 25-50 poor; 0-25 very poor. Minimum requirement for stability is not clear in document, is probably 70. IF THAT IS SO THE CROWN PILLAR WILL NOT BE STABLE AT ANY OF THESE EIGHT HOLES, EVEN IF 300FT THICK.

8 CONCLUSIONS AND RECOMMENDATIONS. We believe that we have made it abundantly clear that the 2006 application document was woefully inadequate, amateurish and intentionally deceptive - which Part 632 describes as felony. Kennecott and their successors do not deny it, apparently relying on time and public indifference to cover up the 4.7 billion dollar crime. We present a small portion of the evidence today to MSHA, from the point-of-view of health and safety, trusting that they will follow through on their vow to "Leave no stone unturned" in their quest to eliminate the occurrence of "Sudden and Unexpected Mining Disasters." Here is one, waiting to happen ..... Look at the photos of diamond-drill cores and ask why they were not made public. SO WHAT IS TO BE DONE? I WOULD REJECT THE APPLICATION, IMMEDIATELY, AS INCOMPLETE AND INADEQUATE AND SERIOUSLY DEFECTIVE, DECEPTIVE, DANGEROUS AND INCREDIBLY INCOMPETENT. It is not unreasonable to assume that anybody who reads this warning and does nothing about it will share the consequences if anything goes wrong at the mine. If there is to be another application I would steer it away from the proposed bulk mining and toward a more selective method, with smaller openings, to be backfilled quickly with strong material. Then the ground could be controlled. Thank you, sincerely, Jack Parker, Mining Engineer/Geologist/Rock Mechanic, Baltic MI 49963, November 25th 2014 There you have my conclusion and recommendations. In case you have the need and the stomach for supporting stories – I have added a short bonus section.

9

A bonus section.

A SHORT, GUIDED TOUR THROUGH THE APPLICATION, POINTING OUT A FEW ADDITIONAL PITFALLS.

THE ROCKTYPES: All of them are very old, Precambrian, pre life on earth, no witnesses. 1. Sedimentary. The ancient equivalent of sandstones and siltstones, altered somewhat by time, pressure and elevated temperature. Generally grey in color. 2. Igneous – formed in fire. Intruded molten from great depth, tens of thousands of feet, into the sediments – fracturing some and thrusting them up and aside, assimilating some and adding juices to some. Generally dark in color and heavy. Recognized by geologists as gabbro, peridotite, feldspathic peridotite and pyroxenite, all closely related. Hornfels is a product of alteration at the contact of igneous and sedimentary rocks. From our design point of view all are much stronger than the sediments. While I have little faith in the compressive strengths given on page 7 of the K/G Geotech report, they are useful for comparison.

Sandstone 9,315 psi, siltstone 10,730 psi.

Feldspathic peridotite 13,340, Gabbro 17,255, Peridotite 17,400

Pyroxenite 19,720, Hornfels 21,170 psi.

Note the ridiculous degree of precision in those numbers.

Never forget that they come from perfect little specimens, not typical of the rock masses. At the bottom of page 10 of the July 7, 2006 Golder report we learn that the crown pillar is comprised primarily of peridotite – so peridotite strength was used in mine design. 17,400 psi. Suspecting malarkey I went to their “Lithologs,” which record rock types and depths in all 27 of the holes deemed representative of crown pillar conditions. They appear in my chart as Figure 4, on the next page.

10

Figure 4. Rock types in 27 DD holes selected by KEMC/Golder for crown pillar study. Faded plum color is peridotite; green color is much weaker sediments. Do you agree that peridotite is the primary rocktype in the crown pillar? (Plum color.) Do you see a considerable proportion of sediments there (green)? Is it fortuitous that they selected peridotite (17,400 psi) and disregarded the sediments (9,135 and 10,730 psi)? How would that affect their predictions of structural stability? When you see the variety of rock types in the crown pillar do you think that it is appropriate to select only one for design purposes? Suppose that you have a pile of 2x4s in your yard – spruce, basswood, pine and oak – would you design your house as if they all exhibited the strength of oak? If K/G were to object that much of the green is in the walls, not the roof of the mine, I would respond by observing that I would not expect the roof of my house to stand if the walls collapsed.

11 A CLOSER LOOK AT ONE OF THE CORES. I chose Hole 67, which is one of the 27 selected by KEMC as being representative of the rocks in the crown pillar. Hole 67 is near the middle of the Lithic Log chart. Depths are given in meters (to confuse? Just multiply by 3.3 to convert to feet). Only the uppermost 300 ft are shown, to include the crown pillar rocks. At Hole 67 the upper 12m (41ft) is sand, clay and gravel. Then comes 27 ft of peridotite, weathered and fractured of course. Then 10.6 ft of hornfels – and 27 ft of pyroxenite, then 35 ft of hornfels, 45 ft of siltstone, 15 ft of hornfels, 27 ft of gabbro, then 277 ft of peridotite. Definitely not all peridotite, right? Now comes the important part: look again at the core photos just inside the front cover of this report. They show the physical condition of cores in the crown pillar. Would you describe it as favorable? Stable? Solid rock? YOUR REACTION IS IMPORTANT BECAUSE THIS IS THE UPPER PORTION OF THE CROWN PILLAR. IT CONTRIBUTES LITTLE OR NO STRUCTURAL STRENGTH BUT ADDS DEAD LOAD. AND YET K/G ALWAYS INCLUDE THOSE UPPER ROCKS IN THEIR CROWN PILLAR THICKNESS AS IF THEY WERE AN ASSET. This is one of those places at which no RMR was assigned – so the hazard did not show on the RMR drawings issued to designers, regulators and reviewers. Obviously the system has been tweaked in many ways to deceive the unwary. I will attach part of the RQD/RMR tabulation to illustrate the omission. See Figure 5 below. Figure 5. RQD/RMR tabulation.

At left, on the RQD chart, the upper 11.89m is sand, clay and gravel. Then come poor rocks. At right the RMRs begin at 38.25m, thus missing 38.25-11.89 =26.36m =87ft of RMRs, which are thus hidden from designers.

12 I’ll show you another way to hoodwink the weary reader. Look at the next figure, Figure 6, which shows the upper part of an RQD log, Hole 101. One is accustomed by now to the idea that K/G works with 3.3m samples, close to 10 ft/box, and one scans the table to get a general impression of core quality. At the top of Hole 101 is a zero, not good, but halfway expected in weathered rocks. Then come a couple of 100s – a nice surprise, somewhat reassuring.

Figure 6. Upper part of RQD log for Hole 101.

Take another look and notice the lengths of those two samples. One is 10” long and the other 12”. So rather than having 20 ft. of excellent core we have less than 2 ft. which survived in lengths greater than 4”. We were deceived. One clue to finding these tricks is to look for a very good number in a group of bad ones. It just doesn’t look right.

This is where “Weighted average” comes in. In calculating averages I “weighted” each RQD by multiplying it by the length of that sample, then divided total product by total length. You can imagine what happens to averages if you either include or omit a bunch of zeroes.

Lest you think that this trickery was confined to the crown pillar I’ll show you a part of Hole 69, at a depth around 400ft – where the RMR is missing from 68 ft of core (Figure 7). That is not in the crown pillar but in the production levels, from 110.5m to 131.06m.

Figure 7. Part of RQD log for Hole 69. Please note the gap in data, from 110.5 to 131.06m = 68 feet! Simply omitted! and nobody noticed! Nobody!

13

Well, here’s just one more obvious “mistake”: THIS IS A FACT: NOBODY CAN PREDICT THE STABILITY OF A CROWN PILLAR UNLESS THE STATE OF STRESS IS KNOWN. WITHOUT THAT INFORMATION THEY ARE GUESSING. The mass of rock, with all its faults and weaknesses, is held in place by horizontal compressive stress, or restraint, NOT BY THE STRENGTH OF LITTLE SPECIMENS. I repeat – NOBODY CAN DO IT. But K/G claim to have done it. Another falsehood. In court we offered a simple demonstration to show the significance of lateral restraint - simple, inexpensive, conclusive and lasting less than half an hour. The judge said “OK.” A standard concrete block in excellent condition (RQD and RMR both 100) was to be held 2 meters (6 feet) above the head of the KEMC lead attorney by his assisting attorney (both having impeccable credentials) as he sits in a comfortable chair, facing the cameras, thoughtfully stroking his moustache, eyes lifted toward heaven. To support the block the lady was to apply only compression to the ends of the block, with her hands. That was the set-up. I would go out for a cup of tea and return in 20 minutes or so, accompanied by a janitor equipped with mop and pail. The attorney cleared his throat and changed the subject, as if to decline the offer. Something similar happened at the nearby Athens iron mine, where a crown pillar of “jaspilite,” a very strong rock, 1800 ft thick, collapsed overnight because it was bounded by near-vertical faults and dikes, with wet and slippery contacts – known locally as “soaprock.” Lateral compression and friction were lacking and the rockmass fell as a plug. Sainsbury was directed, by the DEQ, to remove this case history from his reports, for rather obvious reasons. Incidentally – K/G’s crown-pillar expert told the court that the crown pillar rock (UCS 45,000 psi) resembled wet coffee grounds! Hm. Google Athens report by engineer Allen. In response to our criticism K/G later plugged in values of horizontal stress determined by averaging a large number of measurements reported from the Canadian Shield, thousands of square miles of it. That, of course, is ridiculous and meaningless for our small and specific area of interest. A first-year mining student would not have approved that assumption, which was more evidence of incredible incompetence. K/G could have and should have measured stresses in the outcrop close to the ore body, in a week or so, at a cost of less than $15,000 …….. Enough? You want more? On the next page, p 14, you’ll see the portal site selected by RT and KEMC for the Eagle Mine, the west face of Eagle Rock (Figure 8) . The story issued for public consumption was that they wanted solid rock. Does it look solid to you? Then finally comes another box of core from the crown pillar, your roof rock, as shown on page 15 (Figure 9). Think about it.

14

Figure 8. Portal site selected by Rio Tinto/KEMC for the Eagle Mine.

15

Figure 9. THIS IS AN 8.5-FT. SAMPLE FROM THE "SOLID ROCK" EAGLE CROWN PILLAR.

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16

Figure 10. Excerpt from Michigan’s nonferrous metallic mining regulations, Part 632. Is there any doubt that the KEMC application was made up largely of false statements?

17

We told this to the Michigan DEQ and to MFG in 2007, seven years ago!

MORE COMMENTS ON THE SAINSBURY PAPERS AUGUST 11TH 2007

In the first three papers, a draft report, a final report and a technical memo, Sainsbury provided to the Michigan DEQ and to MFG clear warnings that the conclusions in the mining permit application were inadequate, inaccurate and “not defensible” – which means that they can not be supported by facts. That should have been enough to stop the permitting process immediately. A screeching halt. Then, in a fourth document – the one-page letter dated November 9th 2006, Sainsbury wrote to DEQ and MFG that the information provided did not allow an accurate assessment of crown pillar stability but, for reasons not given, he did not elaborate on that statement. That, of course, did not change the conclusions expressed in his first three documents. In the November 9th letter he said instead that provided mining did not proceed higher than a certain elevation (not clearly defined) … He wrote “It is recommended”, not I recommend, “That the mining permit be limited …” as if implying that it would be granted. HE OMITTED BUT DID NOT WITHDRAW OR ALTER ANY OF THE EARLIER STATEMENTS, WHICH WERE REPEATED MANY TIMES FOR GREATER EMPHASIS. THE MOST TELLING OF THOSE STATEMENTS, WITH WHICH I CONCUR, WAS THAT THE VERY FOUNDATIONS OF THE APPLICATION ANALYSES AND DESIGNS – THE ROCK QUALITY CHARACTERIZATIONS (RQD AND RMR) ON WHICH CALCULATIONS, MODELS AND ILLUSTRATIONS WERE BASED - WERE FAULTY, HENCE MISLEADING. HE HIMSELF HAD TO USE THEM BECAUSE NOTHING BETTER WAS PROVIDED. GIVEN THAT THE ROCK CHARACTERIZATIONS ARE FAULTY – ALL OF THE MINING DESIGNS IN THE APPLICATION ARE ALSO AT FAULT – NOT ONLY THE CROWN PILLAR ANALYSIS. ALL ARE SUSPECT. I recommend that the first three documents be accepted as written, and acted upon. The November 9th letter should be discarded, but only after its raison d’etre has been established. Jack Parker August 11th 2007

18 ACKNOWLEDGEMENTS. Please note that without the know-how and dedication of fellow investigator Laura Gauger completion of this document would not have been possible. Thank you Laura! On a different plane my wife, Levinia, put up with eight years of guff and glumness too. Thank you Vinnie! I love you!

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nder

stan

ding

of

rock

pro

pert

ies

and

beha

vior

– a

nd w

hat

to d

o ab

out

it”.

Som

e pr

ojec

ts a

re o

ne-t

ime,

tro

uble

-sho

otin

g jo

bs.

Oth

ers

are

on-

goin

g, w

ith r

egul

ar in

spec

tions

and

rep

orts

. M

ost

jobs

beg

in w

ith a

pro

blem

, a

tele

phon

e ca

ll fo

r he

lp,

a vi

sit,

a

rem

edy,

and

in s

ome

case

s fu

rthe

r co

oper

atio

n to

ens

ure

that

roc

k-re

late

d pr

oble

ms

do n

ot g

et o

ut o

f ha

nd.

Con

side

red

retir

emen

t in

199

5 bu

t th

at d

id n

ot h

appe

n be

caus

e of

a

cont

inui

ng d

eman

d fo

r pr

actic

al h

elp

(as

oppo

sed

to c

ompu

ter

anal

yses

). As

of t

oday

(20

11)

the

min

d is

will

ing

and

eage

r to

ser

ve

but

the

body

is r

eluc

tant

to

trav

el.

The

wor

k in

clud

es d

esig

n of

und

ergr

ound

min

ing

met

hods

and

layo

uts,

es

peci

ally

con

side

ratio

n of

str

engt

hs a

nd s

tres

ses

in m

ine

roof

, pi

llars

an

d flo

or,

and

supp

orts

. M

odes

t la

b te

sts

are

som

etim

es u

sed,

and

oc

casi

onal

ly s

impl

e, lo

w-c

ost

inst

rum

enta

tion

unde

rgro

und.

Th

e em

phas

is is

on

obse

rvat

ions

at

the

min

e an

d ha

lf a

cent

ury

of

expe

rien

ce w

ith s

imila

r pr

oble

ms

at s

ever

al h

undr

ed o

ther

min

es,

incl

udin

g so

lutio

ns t

o th

ose

prob

lem

s.

Oft

en t

he s

olut

ion

is s

impl

e,

som

etim

es s

o ob

viou

s th

at t

he m

ine

oper

ator

is,

at f

irst

, sk

eptic

al.

App

licat

ion

of c

ompu

ter

mod

elin

g to

min

e de

sign

and

pra

ctic

es is

sp

ecifi

cally

avo

ided

bec

ause

so

ofte

n ba

sic

assu

mpt

ions

are

in

adeq

uate

, in

valid

and

thu

s m

isle

adin

g.

Hav

e ta

ught

sem

inar

s in

pra

ctic

al r

ock

mec

hani

cs a

t M

ichi

gan

Tech

nolo

gica

l Uni

vers

ity,

U o

f N

evad

a at

Ren

o, U

of M

isso

uri a

t Kan

sas

City

, an

d at

Cam

bria

n Col

lege

in S

udbu

ry,

Ont

ario

. At

the

requ

est

of in

dust

ry a

doz

en o

r tw

o ad

ditio

nal s

emin

ars,

tw

o to

fiv

e da

ys e

ach,

hav

e be

en p

rese

nted

at

Whi

te P

ine,

MI,

Mic

higa

n Te

ch,

Bec

kley

W V

A,

Kan

sas

City

, M

O,

and

at in

divi

dual

min

ing

prop

ertie

s.

Dur

ing

grad

uate

wor

k ta

ught

cou

rses

in g

laci

al g

eolo

gy a

nd

geom

orph

olog

y at

Mic

higa

n Te

ch.

Dur

ing

1971

and

’72

taug

ht r

ock

mec

hani

cs a

nd r

ock

frag

men

tatio

n at

M

ichi

gan

Tech

(tw

o da

ys/w

eek)

.

b)

1961

– 1

971,

ten

yea

rs a

t th

e W

hite

Pin

e co

pper

min

e, W

hite

Pin

e, M

I.

Fi

rst

year

was

as

a m

ine

fore

man

, on

und

ergr

ound

dev

elop

men

t.

Nex

t tw

o ye

ars

as a

res

earc

h en

gine

er,

on d

rilli

ng,

blas

ting

and

roof

-bo

lting

pro

ject

s, in

clud

ing

han

ds-o

n in

trod

uctio

n of

AN

FO

unde

rgro

und,

wor

king

with

drille

rs a

nd p

owde

rmen

. Sev

en y

ears

as

Direc

tor

of R

ock

Mec

hani

cs,

with

3 o

r 4

eng

inee

rs a

nd

up t

o 10

tec

hnic

ians

, de

alin

g m

ainl

y w

ith m

inin

g la

yout

s, m

inin

g m

etho

ds a

nd m

ine

stab

ility

and

sup

port

s fo

r th

is 2

5,00

0 to

ns/d

ay

hard

rock

und

ergr

ound

ope

ratio

n.

c)

19

61,

one

year

with

R.

L. L

oofb

ouro

w,

min

ing

cons

ulta

nt,

out

of

Min

neap

olis

. d)

19

54 –

196

1, a

t M

ichi

gan

Tech

. F

our

year

s on

tw

o B.S

. de

gree

s

follo

wed

by

thre

e ye

ars

for

a M

aste

r’s

degr

ee w

hile

tea

chin

g pa

rt-t

ime

in t

he G

eolo

gy D

ept.

W

orke

d du

ring

all

vaca

tions

in g

old

and

nick

el

and

iron

min

es in

Ont

ario

and

Que

bec.

e)

1953

– 1

954,

hav

ing

emig

rate

d fr

om U

.K.

to C

anad

a, w

orke

d as

a

su

rvey

or/e

ngin

eer

on m

ine

shaf

t-si

nkin

g an

d de

velo

pmen

t pr

ojec

ts o

n H

udso

n’s

Bay

NW

T, a

nd a

t Sud

bury

, H

aile

ybur

y, B

ancr

oft

and

Nor

th

Bay

Ont

ario

, fo

r Te

mis

kam

ing

Con

stru

ctio

n Lt

d.

f)

19

46 –

1953

, w

orke

d in

coa

l min

es in

Eng

land

, fo

r on

e ye

ar a

s an

of

fice

boy,

the

n si

x ye

ars

in s

urve

ying

, pl

anni

ng a

nd e

ngin

eering

at

a gr

oup

of fou

r m

ines

, un

der

the

Nat

iona

l Coa

l Boa

rd.

3.

ED

UCATI

ON

.

Hig

h sc

hool

in E

ngla

nd.

Nig

ht s

choo

l and

par

t-tim

e fu

rthe

r sc

hool

ing

in E

ngla

nd,

unde

r N

atio

nal C

oal B

oard

edu

catio

n sc

hem

e.

1954

, to

Mic

higa

n Te

ch.

1958

, B.

S.

Min

ing

Engi

neer

ing.

B

.S.

Geo

logi

cal E

ngin

eering

.

G

rade

poi

nt a

vera

ge 3

.75/

4.00

.

P

ositi

on in

cla

ss 4

/384

. 19

60,

M.S

. G

eolo

gy (

Thes

is:

Sub

lacu

strine

Geo

logy

of

East

ern

Lake

Sup

erio

r).

G

rade

poi

nt a

vera

ge 4

.00/

4.00

.

4.

PU

BLIC

ATIO

NS A

ND

AW

ARD

S.

Au

thor

s ar

e lis

ted

alph

abet

ical

ly.

Park

er a

nd S

cott

, In

stru

men

tatio

n of

Roo

m a

nd P

illar

Wor

king

s, P

roc.

6th S

ymp

on

Roc

k M

echa

nics

, Rol

la M

O 1

964.

Cum

min

gs a

nd P

arke

r, T

he W

hite

Pin

e H

ydra

ulic

Cel

l, Pr

oc.

6th S

ymp

on R

ock

Mec

hani

cs,

Rol

la M

O 1

964.

Pa

rker

, Th

e W

hite

Pin

e Sag

met

er,

E/M

J M

ay 1

965.

Sco

tt,

Mic

hels

and

Par

ker,

The

Rol

e of

Roc

k M

echa

nics

in M

ine

Sta

bilit

y, N

atio

nal

Saf

ety

Cou

ncil

New

slet

ter,

Mar

ch 1

966.

G

arfie

ld a

nd P

arke

r, R

ock

Mec

hani

cs,

an O

pera

tions

Too

l at

Whi

te P

ine,

Min

Con

g Jo

urna

l, Ju

ne 1

966.

Pa

rker

, H

ow M

oist

ure

Affec

ts M

ine

Ope

ning

s, E

/MJ

Nov

196

6.

Park

er,

Min

ing

in a

Lat

eral

Str

ess

Fiel

d at

Whi

te P

ine,

Can

IM

M T

rans

v L

XIX

196

6.

“A s

emin

al p

aper

”.

Bar

rien

tos

and

Park

er,

Use

of th

e Pr

essu

re A

rch

in M

ine

Des

ign,

AIM

E pr

eprint

69-

AM

-369

, Se

pt 1

969.

Al

so A

IME

Tran

s Sep

t 19

74.

SM

E Rob

ert

Peel

e aw

ard

for

“sig

nific

ant

achi

evem

ent

in a

utho

rshi

p in

the

fie

lds

of m

inin

g an

d Roc

k M

echa

nics

, Rol

la M

O 1

964.

Aga

pito

and

Par

ker,

Dev

elop

men

t of

a B

ette

r Roc

kbol

t Ass

embl

y at

Whi

te P

ine,

AIM

E an

nual

mee

ting

Feb

1970

. Pa

rker

, Te

mpe

ratu

re a

nd H

umid

ity

Affec

t Str

engt

h of

Roc

k Str

uctu

res

at W

hite

Pin

e,

SM

E Tr

ans

June

197

0.

Cav

erso

n an

d Pa

rker

, Roo

fbol

ts H

old

Bes

t W

ith R

esin

, M

in E

ng M

ay 1

971.

Pa

rker

, PR

ACTI

CAL

RO

CK M

ECH

AN

ICS

FOR M

INER

S,

a se

ries

of

seve

n ar

ticle

s in

E/

MJ,

beg

inni

ng J

une

1973

. S

ever

al t

hous

and

repr

ints

stil

l in

use,

plu

s th

ousa

nds

of

unau

thor

ized

pho

toco

pies

, in

clud

ing

a tr

ansl

atio

n in

to S

pani

sh b

y th

e M

exic

an

equi

vale

nt o

f th

e U

SBM

. G

ood

for

busi

ness

. Pa

rker

, th

e Fi

rst

Cop

per

Min

ers

in M

ichi

gan,

Com

pres

sed

Air M

agaz

ine,

Jan

197

5.

Pete

rsen

, Pl

umea

u an

d Pa

rker

, Yi

eldi

ng P

illar

s an

d Pr

essu

re A

rche

s at

Cay

uga

Salt

Min

e, N

Y, S

ME

prep

rint

, Key

ston

e 19

77.

Als

o E/

MJ

May

197

9. AIM

E aw

ard

for

“out

stan

ding

con

trib

utio

ns in

roc

k m

echa

nics

, 19

81”.

Pa

rker

, Pi

llar

Des

ign

– Pr

oble

ms

or O

ppor

tuni

ties?

1st

Con

f on

Sta

bilit

y in

U

nder

grou

nd M

inin

g, V

anco

uver

, Aug

198

2.

Park

er,

Min

e Pi

llar

Des

ign

in 1

993:

Com

pute

rs H

ave

Bec

ome

the

Opi

ate

of M

inin

g En

gine

ers,

Min

Eng

tw

o pa

rts,

Jul

y an

d Aug

199

3.

Park

er,

Ever

ybod

y go

es U

nder

grou

nd E

vent

ually

, Ag

greg

ates

Man

ager

, Ju

ne 1

996.

Park

er,

The

Mis

appl

icat

ion

of C

ompu

ter

Tech

nolo

gy t

o M

ine

Des

ign

– an

d th

e H

ome

Rem

edy,

Agg

Man

Oct

199

9.

Park

er,

Ano

ther

Mis

appl

icat

ion

of C

ompu

ter

Tech

nolo

gy,

this

tim

e to

Min

e Pi

llar

Des

ign

(and

Ano

ther

Hom

e Rem

edy)

, A

gg M

an M

ay 2

000.

A m

ajor

pub

licat

ion

on R

ESIN

BO

LTIN

G,

follo

wed

res

earc

h at

Mic

h Te

ch,

unde

r U

SBM

co

ntra

ct #

JO 3

6600

4, J

uly

1977

. P

arke

r re

port

ed s

egm

ent

on t

he f

ield

res

earc

h in

so

me

40 c

oal m

ines

in t

he U

S,

Fran

ce a

nd E

ngla

nd,

with

man

y ill

ustr

atio

ns.

5.

LIST

OF

CLI

ENTS

. Alli

ed C

hem

ical

, W

Y, t

rona

. AM

AX,

IN,

MI,

NM

, W

Y, c

oal,

copp

er,

pota

sh,

tron

a.

Am

eric

an E

lect

ric

Pow

er,

UT,

coa

l. Am

eric

an M

ine

Ser

vice

s, W

I, c

oppe

r, g

old.

Am

eric

old,

Kan

sas

City

KS,

unde

rgro

und

limes

tone

and

spa

ce d

evel

opm

ent.

Ana

cond

a, M

T, c

oppe

r.

Arc

hiba

ld M

inin

g an

d En

gine

erin

g Con

sulta

nts,

con

sulti

ng o

n un

derg

roun

d lim

esto

ne.

ASARCO

, TN

and

CO

, le

ad,

zinc

. Bar

don-

Trim

ount

, M

A,

crus

hed

rock

. Bas

s Pr

o-Sho

ps,

MO

, un

derg

roun

d sp

ace.

Bla

ck R

iver

Min

ing,

KY,

lim

esto

ne.

Boa

tmen

’s B

ank,

MO

, lim

esto

ne.

Boo

ne Q

uarr

ies,

MO

, un

derg

roun

d lim

esto

ne a

nd s

pace

. Cal

laha

n M

inin

g, M

I, g

old.

Cal

law

ay M

inin

g, K

C M

O,

unde

rgro

und

min

ing

and

spac

e.

Cal

mat

Cor

p, C

A,

crus

hed

rock

, un

derg

roun

d?

Can

adia

n Roc

k Sal

t, O

NT

and

Nov

a Sco

tia,

rock

salt

. Car

gill

Sal

t, L

A a

nd N

Y, r

ocks

alt.

Cel

tite,

res

in b

oltin

g.

Clif

fs E

ngin

eering

, CO

, na

hcol

ite,

(sol

utio

n m

inin

g).

Com

mer

cial

Dis

trib

utio

n Cen

ter,

KC M

O,

unde

rgro

und

spac

e.

Com

mer

cial

Sto

ne,

PA,

limes

tone

. Con

tinen

tal C

emen

t, M

O,

limes

tone

. Con

tinen

tal M

iner

als,

NV,

talc

. Cur

ragh

Res

ourc

es,

Nov

a Sco

tia,

coal

. Cyp

rus

Min

es,

CO

, PA

and

WY,

coa

l. D

etro

it Sal

t, M

I, r

ocks

alt.

D

icke

nson

Red

Lak

e, O

NT,

gol

d.

Dom

tar

Min

eral

s, O

NT,

LA a

nd M

I, g

ypsu

m a

nd r

ocks

alt.

D

ravo

, KY,

lim

esto

ne.

Eart

h Sci

ence

s In

c, U

T, u

rani

um.

East

Mal

artic

, Q

uebe

c, g

old.

El

mhu

rst

Cru

shed

Sto

ne,

IL,

limes

tone

. En

viro

nmen

t O

ne,

MA,

unde

rgro

und

fire

dete

ctio

n.

Exxo

n, W

Y, u

rani

um.

Fairm

ount

Dev

elop

men

t, K

C M

O,

unde

rgro

und

spac

e.

Gar

ney

Com

pani

es,

KC M

O,

unde

rgro

und

spac

e.

Gen

eva-

Paci

fic,

AK,

copp

er.

Gra

sis

Cor

p, K

C M

O,

unde

rgro

und

spac

e.

Gre

enbr

ier

Agg

rega

tes,

PA,

limes

tone

.

Gries

emer

Qua

rrie

s, M

O,

limes

tone

and

und

ergr

ound

spa

ce.

Hill

top

Basi

c Res

ourc

es,

KY,

lim

esto

ne u

nder

grou

nd?

Hol

land

Qua

rrie

s, K

C K

S,

unde

rgro

und

limes

tone

and

spa

ce.

Hom

esta

ke M

inin

g, S

D,

gold

. H

unt-

Mid

wes

t, K

C M

O,

unde

rgro

und

limes

tone

and

spa

ce.

Inla

nd S

teel

, IL

, co

al.

Inte

rnat

iona

l Sal

t, O

H a

nd N

Y, r

ocks

alt.

J

M H

uber

Cor

p, I

L an

d G

A,

limes

tone

. Jo

urna

gan

Cru

shed

Sto

ne,

MO

, lim

esto

ne u

nder

grou

nd?

Kem

mer

er C

oal,

WY,

coa

l. Ker

r-M

cGee

, IL

and

NM

, co

al,

pota

sh.

Kim

berley

Cla

rk,

MI,

min

ing

leas

es.

Kin

caid

Sto

ne,

IL,

limes

tone

. La

Farg

e, M

O a

nd N

Y, li

mes

tone

. Le

hman

, M

N,

plat

inum

gro

up m

iner

als

deep

und

ergr

ound

. Lo

ne S

tar

Cem

ent,

W V

A,

limes

tone

. Lo

ring

Qua

rrie

s, K

C K

S,

limes

tone

and

und

ergr

ound

spa

ce.

Loui

sian

a La

nd,

MI,

cop

per.

Lo

uisv

ille

Cru

shed

Sto

ne,

KY,

lim

esto

ne.

Mac

assa

Min

es,

ON

T, g

old.

M

aple

Mea

dow

, W

VA,

coa

l. M

arbl

ehea

d Li

me,

lim

esto

ne.

Mar

ley

Engi

neer

ing,

KC M

O,

unde

rgro

und

spac

e.

Mar

tin-M

arie

tta,

IA,

NE

and

MO

, lim

esto

ne.

MIC

ARE,

Mex

ico,

coa

l. M

iner

al T

echn

olog

ies,

CA,

lim

esto

ne.

Min

go-L

ogan

Coa

l, W

VA,

coal

. M

issi

ssip

pi L

ime,

IL,

MO

and

VA,

limes

tone

. M

isso

uri L

imes

tone

, M

O,

limes

tone

. M

onte

rey

Coa

l, (E

XXO

N)

IL a

nd W

VA,

coa

l. M

orto

n Sal

t, O

H,

Nov

a Sco

tia a

nd L

A,

rock

sal

t.

Nat

iona

l Par

k Ser

vice

s, U

T, t

unne

l sta

bilit

y.

Nat

iona

l Wild

life

Fede

ratio

n, M

I, K

enne

cott

Eag

le M

ine

perm

ittin

g.

NM

Att

orne

y G

ener

al,

re W

IPP

at C

arls

bad

NM

. N

oran

da M

ines

, Q

uebe

c, g

old.

O

rvan

a M

I, c

oppe

r su

lfide

. O

zark

Lea

d, M

O,

lead

. Pa

rkvi

lle S

tone

, KC M

O,

limes

tone

and

und

ergr

ound

spa

ce.

Pars

ons-

Jurd

en,

ID,

vana

dium

. Pf

izer

, N

V t

alc,

CA

and

MD

lim

esto

ne.

Pion

eer-

Mid

Atla

ntic

, PA

, lim

esto

ne.

Prin

cipi

a Col

lege

, IL

, lim

esto

ne u

nder

grou

nd?

Reo

cin

Min

es,

Spa

in,

zinc

, le

ad.

Riv

ersi

de C

emen

t, C

A,

limes

tone

. Rog

ers

Gro

up,

IN,

KY

and

TN,

limes

tone

. Roy

al O

ak M

ines

, O

NT,

gol

d.

Sel

lers

burg

Sto

ne,

IN, lim

esto

ne u

nder

grou

nd.

Soi

ltest

Inc

, IL

, in

stru

men

tatio

n.

S E

Pub

lic S

ervi

ces,

KC K

S, u

nder

grou

nd li

mes

tone

and

spa

ce.

Sou

ther

n Illin

ois

Sto

ne,

limes

tone

. Sou

ther

n U

tah

Coa

l, U

T, c

oal.

Sto

neco

, IN

and

OH

, lim

esto

ne u

nder

grou

nd?

Texa

sgul

f, W

Y tr

ona

and

NB

limes

tone

.

3M,

MN

, re

sin

roof

-sup

port

sys

tem

s.

Tim

na M

ines

, Is

rael

, co

pper

. U

nder

grou

nd D

evel

oper

s Ass

n, K

C M

O,

unde

rgro

und

spac

e.

Uni

sil,

MN

and

WI,

sili

ca s

and.

U

noca

l, CO

, oi

l sha

le.

USBM

, nu

mer

ous

proj

ects

. U

.S S

teel

, W

VA,

coa

l. U

V I

ndus

trie

s, N

M,

copp

er,

zinc

. W

estin

ghou

se,

CO

, in

stru

men

tatio

n.

Wes

troc

, O

NT

and

MI,

gyp

sum

. W

hite

Pin

e Cop

per

, M

I, c

oppe

r.

Wim

pey

Min

eral

s, P

A,

limes

tone

. W

inch

este

r Cen

ter,

KC M

O,

unde

rgro

und

spac

e.

WIP

P, W

aste

Iso

latio

n Pi

lot

Proj

ect,

NM

, in

roc

k sa

lt.

Yava

Min

es,

Nov

a Sco

tia,

lead

. All

the

abov

e w

ere

unde

rgro

und

oper

atio

ns.

Tho

se fol

low

ed b

y a

ques

tion

mar

k (e

.g.

Sto

neco

, IN

and

OH

, lim

esto

ne?)

wer

e co

ntem

plat

ing

goin

g un

derg

roun

d.

Expe

rt w

itnes

s in

mor

e th

an a

doz

en la

w c

ases

. Reg

iste

red

Prof

essi

onal

Geo

logi

st in

MO

, #

0088

, no

w la

psed

.