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transcript
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.
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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.
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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.
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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.
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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!
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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.
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Figure 8. Portal site selected by Rio Tinto/KEMC for the Eagle Mine.
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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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ine
as “
an u
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
.