2008-05-05_APPLICATION CORRESPONDENCE - C2008086

• Permit No: C2008086
• IBM Index Class Name: APPLICATION CORRESPONDENCE
• Doc Date: 5/5/2008
• Doc Name: Incompleteness Letter
• From: DRMS
• To: CAM-Colorado, LLC
• Email Name: MPB
• Media Type: D
• Archive: No

Mr. Gary Isaac
May 5, 2008
Page 4
Please update the permit application sections 2.04.5, 2.04.7, and 2.05.6. to include an impact
analysis for Big Salt Wash. The Division will need this information for input to a
Cumulative Hydrologic Impact Analysis (CHIA) for the entire life of mining operation. The
PHC information and the CHIA will have to address impacts to both Big Salt Wash as well
as East Salt Creek.
5. It is stated in the application that "The coal seam analytical data are obtained from two grab
samples from the McClane Canyon Mine and some historic information from Snowcap Coal
Company's permit." The geochemical analyses of the coal seam and strata above and below the
coal seam are presented in Volume III, Exhibit 6. Rules 2.04.6(3) (iii) and (iv) require site
specific geologic baseline information for the lands within the permit area. Rule 2.04.6(3) (b) does
allow an applicant to request the Division to waive in whole or in part these requirements. The
waiver maybe granted only if the Division makes a written determination that the collection and
analysis of such data is unnecessary because other equivalent information is available to the
Division in a satisfactory form. To consider the application complete, the required site specific
geologic data is needed or a waiver request justifying the reasons why CAM-Colorado believes
site specific data is not necessary.
Additionally the following information and submittal requests (Items 6 through 11) will be needed for the
Division to complete a thorough adequacy review of the permit application package.
6. Rules 2.04.7(1) & (2) require location information and descriptions of all springs within the
permit and adjacent areas. Very little information is provided on the occurrence of springs in the
area. On page 2.04-9, CAM-Colorado indicates "...only a few springs exist within the coal
bearing strata." In accordance with 2.04.7 and 2.05.3 please provide a spring and seep survey
for the entire estimated life of mine operations area and clarify the location of the springs
referenced on page 2.04.9.
7. The baseline surface water data presented for East Salt Creek appears to be lacking the some of
the minimum parameters required by Rule 2.04.7(2). For ESC-1 both total and dissolved iron are
required and at ESC-2 total suspended solids, iron, and manganese appear to be missing from the
analyses. If these data are available please update Volume III, Exhibit 3 accordingly.
8. The Alluvial Valley Floor Determination presented in Volume III, Exhibit 12 does not specifically
include the information identified by our Division in a letter dated May 22, 2006 regarding our
informal alluvial valley floor findings. The AVF study also appears to be lacking detailed
operational information (for example mine water discharge locations). There are two areas of
alluvium that need to be addressed one along East salt Creek and one along Big Salt Wash. These
specifically are where mine water discharge enters East Salt Creek down to the Highline Canal.
Likewise, to the east where mine discharge would likely enter into Big Salt Wash down to the
Highline Canal. The Division believes that AVF Study needs to be revised to include these