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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 11 <br />single data point for the aquifer/saturated zones above, within, and below the lowest coal <br />seam to be mined. For the bedrock groundwater, the location and extent of sub-surface <br />water is not fully characterized within the proposed permit and adjacent areas. Only very <br />general information was provided on groundwater flow direction and gradient and no <br />information was given regarding the recharge, storage, and discharge characteristics of <br />the aquifers/saturated zones. At a minimum, up gradient and down gradient monitoring <br />wells should be established to identify variations in groundwater characteristics including <br />quantity and quality throughout the permit area and adjacent areas. In particular the <br />northern portion of the permit area has virtually no monitoring wells except for one well <br />located above the coal seam in Section 34. Please provide a plan and schedule for <br />installing at least three additional baseline monitoring wells one for each of the zones <br />above, within, and below the Cameo coal horizon. <br />Rule 2.04.9 Soils Resource Information <br />Soil Resource Information is presented in Section 2.04.9, Exhibit 7-Baseline Soil Survey, and <br />Map-04 Soils. Information addressing the requirements of Rules 2.04.9(1)(a) through (e) is <br />provided in these sections, and the intensity of sampling appears to have been adequate to <br />comply with 2.04.9(2). The applicant has not proposed to use selected overburden materials as a <br />supplement or substitute to topsoil, pursuant to 2.04.9(3). The Division has the following <br />comments regarding this section. <br />31. Map-04 properly includes soil sample locations and also denotes proposed topsoil (top <br />lift) salvage thickness for each map unit. The map should also specify subsoil (second <br />lift) salvage thickness for particular map units, pursuant to Rule 2.04.9(l)(c)(ii). The <br />applicant has proposed such 2nd lift salvage within map units A and E. The Division <br />believes 2"d lift salvage is warranted in additional map units as well, as recommended in <br />the consultant's report in Exhibit7. Also, on Map-04, a number of the proposed salvage <br />depths are obscured by road and permit boundary delineations. <br />Please amend the map to include 2°d lift as well as I" lift salvage thicknesses, and ensure <br />that the thicknesses for each map unit are clearly legible. <br />Rule 2.04. 10 Vegetation Information <br />An outline description addressing the requirements of Rules 2.04. 10 (1) through (5) is presented <br />in Section 2.04.10. Detailed information including vegetation community descriptions, affected <br />and reference area data, and evaluation of potential impacts to rare and endangered plant species <br />is provided in Exhibit 5-Baseline Vegetation Survey. Required map information is provided on . <br />Map-03 Vegetation, and Map E5-1 of Exhibit 5.