Laserfiche WebLink
Gary Isaac <br />CAM-Colorado, LLC <br />August 29, 2008 <br />Page 24 <br />earthwork in the steep slope areas. Address how the deep fills as depicted in cross- <br />sections C-C, D-D, and other locations will be excavated and how the material will be <br />placed, compacted, and stabilized at the final slope grades depicted. <br />Rule 2.05.6(2) Fish and Wildlife Plan <br />60. Please refer to the enclosed comment letter from the USFWS. The USFWS has <br />identified several concerns including avoidance of impacts to the threatened, endangered <br />and candidate species, as well as species-at-risk and their habitats within the project <br />areas, depletions to the Colorado River System, electricity transmission lines and power <br />lines associated with this project and their conformance to specific guidelines (which are <br />enclosed with the USFWS letter). USFWS is recommending that CAM conduct Raptor <br />and Migratory bird surveys and Prairie dog surveys. Please respond to these concerns <br />and update the PAP accordingly. <br />Rule 2.05.6 3 Protection of Hydrological Balance <br />61. During our completeness review of the PAP, the Division requested CAM to update the <br />application to include all disturbances associated with vent shafts including required road <br />construction to access the shaft sites. CAM responded in the May 22, 2008 letter stating that <br />"There are no anticipated ventilation shafts during the life of operation as defined on <br />amended page 2.05-2." Yet on page 2.05-99, the application still states that ventilation <br />shafts could cause water to move from formations above the coal seam into the mine. <br />Please clarify this discrepancy and amend the application accordingly. <br />62. There are no specific probable hydrologic consequences (PHC) given for groundwater. On <br />page 2.05-102 and 103, respectively CAM states that leachate from the coal mine waste <br />disposal area and the clean coal stockpile area could slightly increase the iron and <br />manganese concentration in the ground water. There is no quantification or prediction <br />given, and it is unclear what specific ground water is being referred to. Please clarify this <br />and revise pages 2.05-102 and 103 accordingly. Please provide specific PHC predictions for <br />alluvial and the bedrock groundwater. <br />63. On page 2.05-102 CAM states that leachate from the gob pile will lower conductivity and <br />TDS concentrations in the groundwater in the vicinity of the coal mine waste disposal area <br />and the groundwater along East Salt Creek. Please describe the migration pathway for <br />leachate to enter East Salt Creek and provide some quantification for this prediction of <br />lowered TDS concentrations in the groundwater along East Salt Creek. <br />64. No PHC predictions or analysis are provided for the mine water discharge that will be <br />discharged to the surface stream below the portal and the stream/mine water flow path <br />shown on Map 23 that could potentially enter shallow alluvial groundwater and East Salt