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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 19 <br />46. In the Sedcad design for pond A, on page A-4, the reference area percent litter for Juniper <br />Shrub is listed as being 17.4 and the percent ground cover as being 34.8. However, <br />referring to Table E54 of Exhibit 5 in Volume III, it appears the reference area litter <br />percent for Juniper Scrub is 21.96, resulting in a ground cover of 43.9 percent. Although <br />this doesn't change the curve number, the discrepancy might lead to future confusion. <br />Please revise. <br />47. In the Sedcad design for pond A, on page A-5, there is an entry for desert shrub with a <br />fair hydrologic condition and a curve number of 86. However, there is no curve number <br />86 verification information as was done for the other curve numbers on pages A-3, A-4 <br />and A-5. Please provide this information. <br />48. On page D-5 of the curve number determination for pond D, a curve number of 89 is <br />given for the greasewood community but is listed as 84 in the runoff volume calculation. <br />Please revise accordingly. <br />49. On pages F-3 and F-4 for pond F, the curve number determinations for the two sagebrush <br />communities appear to have incorrect information. In both cases, the cover type is listed <br />as being desert shrub although the vegetation community is listed as being sagebrush. In <br />addition, both curve numbers for the sagebrush communities are shown as being 88 <br />although they are listed as being 55 and 70 in the run-off volume calculation for pond F. <br />Please explain or revise. <br />50. Please revise the text on page 2.05-34 of Volume I to male it clear that there will be a <br />pump permanently installed at each of ponds A, D and E. <br />51. A stability analyses for the sediment ponds is referenced on page 2.05-33 and is <br />presented in Volume III, Exhibit 16. In Exhibit 16 it is stated that one or more of the <br />proposed ponds at the Red Cliff Mine would be categorized as a "Class B" dam since <br />failure could cause damage to Highway 139. Two scenarios were analyzed in the <br />stability analysis Case 1 (subsoil consists of overburden and Case 2 ( subsoil consists of <br />weathered claystone). The ponds that the stability analyses were prepared for are not <br />identified in Exhibit 16 or on page 2.05-33. Please identify the ponds categorized as <br />Class B in the stability analysis and provide a description of these ponds in text on page <br />2.05-33. Please ensure that these ponds meet the safety factor requirements of Rule <br />4.05.9(8) (a). <br />Rule 2.05.3(4) (a) (ii) (B) requires the applicant to include any geotechnical investigation <br />to ensure compliance with the safety factor requirements of Rules 4.05.6 and 4.05.9. <br />Therefore, in accordance with 4.05.9(8)(b), any impoundment not meeting the size or <br />other criteria of 30 CFR 77.216(a), and located where failure would not be expected to <br />cause loss of life or serious property damage, shall have a minimum static safety factor of <br />1.3 for a normal pool with steady state seepage saturation conditions. The Division