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Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 Page 23 <br />Rule 2.05.3(8) Coal Mine Waste and Non-Coal Processing Waste <br />57. Narrative in the first two paragraphs of page 2.05-48, and various other sections within <br />the application, describes a two phased coal mine waste pile design, as well as likely <br />future expansion beyond the phase I and phase II. The phase I area is described as having <br />a capacity of 8.5 million tons ("about 36% more than the estimated coal mine waste to be <br />produced during the initial five year permit term"). Since the operational life upon which <br />this permit review is based is only 6 years, we presume the Phase I design would be <br />sufficient to handle all of the coal waste to be produced during the 6 year period, and that <br />the pile design described in the final three sentences of the first paragraph on page 2.05- <br />48, and depicted on Map 15-6 and various other permit application maps, is the Phase 1 <br />design pile. <br />Please confine that this is the case, and add appropriate clarifying language to the page <br />2.05-48 narrative. Please further amend the text to clarify that any long term expansion <br />of the waste pile beyond the Phase 1 design depicted and described would be contingent <br />upon submittal and approval of a permit revision that would address extension of the <br />operational life beyond that currently proposed. <br />58. Narrative on page 2.05-48 states that side slopes of the pile "are no steeper than 3H: <br />IV..." We believe 3:1 (33%) is appropriate as a maximum grade, but based on review of <br />Map 15-6 and Map 18, slopes along the west side of the pile appear to approach 2:1 <br />(50%). Please address this apparent discrepancy, and amend the plan as necessary. <br />Rule 2.05.4(2)(c) Backfilling and Grading <br />59. We have many of the same concerns with the Backfilling and grading plan, particularly <br />with respect to final reclamation grading of the steep portal facility area, as previously <br />expressed with regard to the final grading plan for the upper Haul Road 1 segments in <br />steep topography. Restoration of the "exact original topography", as indicated by the <br />combination premining/postmining topography maps would not be realistic, nor would it <br />result in stable postmine slopes in such steep terrain. Backfilling to eliminate steep cuts <br />in the portal vicinity would result in fill slopes up to 100% in some areas (see cross- <br />section C-C, and adjacent slope areas). <br />A realistic backfill and grading plan, with revised postmining contours and cross- <br />sections, and demonstration that "worst case" backfill slopes will achieve a minimum <br />static safety factor of 1.3, pursuant to Rule 4.14.2(1)(b), will need to be provided. <br />Narrative will need to be revised to correspond to amended postmining maps and cross- <br />sections. Upper and lower perimeters of proposed reclamation backfill, as well as upper <br />and lower limits of disturbance associated with operational cut and fill should be <br />delineated on the topographic maps and cross-sections. Also, please include description <br />of the types of equipment and techniques that will be used to perform the reclamation