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March 30, 2006 <br />Mr. Byron Walker <br />Re.~ Hayden Gulch Loadout, Permit C-91-081 <br />Responses to Midterm Permit Comments <br />Page 8 <br />Rule 2.05.3(3)(c)(vid) <br />Item 15. No certified profile was found for haul road HGLF-HRI. Please add a certified profile <br />to the PAP. <br />Response: Haul road HGLF-HRl was designed and constructed in the 1978/1979 period by the <br />previous owner and permittee, H-G Coal Company. Since this time period is before August 1, <br />1995, in accordance with Rule 4.03.1(1)(d)(ii) HGTI believes a relevant showing that the road meets <br />the performance standards of Rule 4.03.1 is warcanted rather than a construction certification. This <br />is especially true since HGTI personnel are unable to locate information pertaining to the design and <br />construction of this road and, therefore, can not certify the design or construction as required per <br />Rule 2.05.3(3)(c)(vii). <br />A review of CDMG's monthly compliance inspection reports since 1992 indicates that CDMG has <br />never had an issue or identified problems with this haul road. There are no maintenance requests, or <br />other comments that indicate the road is out of compliance with the performance standards of Rule <br />A.O5.1. HGTI is sure if CDMG had an issue with the construction or maintenance of this road or, if <br />it felt it did not meet the performance standards of Rule 4.05.1, CDMG's concerns would have been <br />brought to HGTI's attention in one of the monthly compliance inspection reports or permit reviews <br />conducted by CDMG since 1992. This is evidence that the road meets the performance standards of <br />Rule 4.05.1 and consequently, demonstrates that a certified profile is un-necessary. <br />However, to address this comment, HGTI has developed a profile of the existing road configuration <br />using survey data collected in November 2005. The profile drawing should be inserted into the PAP <br />as Appendix 12-SA, Haul Road HGLF-HRI Plan and Profile. The certification statement attached <br />to this drawing only covers the existing profile and not the actual design or construction. <br />Item 16. No certified profile or cross sections were found for the access road The only plan <br />view of the access road is on Drawing 12-1 and Drawing 12-2. Please clarify as <br />suggested above. <br />Response: In response to CDMG's comment, HGTI surveyed the profile(s) of HGLF-HRI (as <br />noted above), and what Exhibits 12-1 and 12-2 showed as an access road that extended from the <br />Truck Dump Hopper, past the Office/Change House to haul road HGLF-HRl (this alignment is <br />shown on both the pre-TR-06 and TR-06 drawings). As a result of the survey, it came to our <br />attention that there actually are two parallel roads following a similar alignment - a "light-use" road <br />and an "access road." This road alignment is shown on Exhibit 12-1 (Revision 13) and Exhibit 12-2 <br />(Revision 10). The light-use road is the outside road (between ditches 1 and 2), and the access road <br />is on the inside - it crosses over culvert LFC-1. <br />The facilities area access road was designed and constructed in the 1978/1979 period by the <br />previous owner and permittee, H-G Coal Company. Since this time period is before August 1, <br />1995, in accordance with Rule 4.03.2(1)(f)(ii) HGT[ believes a relevant showing that the road meets <br />the performance standards of Rule 4.03.2 is warranted rather than a construction certification. This <br />is especially true since HGTI personnel are unable to locate information pertaining to the design and <br />Hydro-Environmental Solutions, Inc. <br />P.O.Box772990 <br />57 10'" Street, Suile B <br />Steamboat Springs, C080477 <br />(970) 871-6/25 <br />