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Gary Isaac <br />CAM-Colorado, UC <br />August 29, 2008 <br />Page 5 <br />Please add a discussion of the geologic hazards to the permit text in 2.04.6 and add a <br />reference to Map 05 along with the Geologic Evaluation Report and Geotechnical Study <br />prepared by Vector. Since potentially unstable slopes and areas of accelerated erosion <br />exist, the revised text should contain a plan to minimize disturbance in these areas. The <br />mitigation measures recommended by the Vector report and study are not currently in the <br />PAP. A mitigation plan to ensure the stability of these facilities should be developed and <br />implemented during and after construction to ensure the safety of both infrastructure and <br />personnel. <br />14. The outcrop burn from the Hotpoint Fire is shown on Map 26. Please delineate the Hot <br />Point Outcrop fire zone on Map 05 Surficial Geology & Geologic Hazards. Clarification <br />should be provided regarding location of the outcrop fire and coal seam(s) affected by the <br />fire, proximity of proposed surface disturbance to the outcrop fire, and coal seams that <br />would potentially be extracted in the vicinity of the outcrop fire. The potential for the <br />proposed project to exacerbate the existing outcrop fire should be assessed, and <br />mitigation measures (including avoidance) should also be addressed. Please update <br />Section 2.04.6 Geology Description accordingly. <br />15. The geochemical analyses discussion of the Cameo Coal Seam presented on page 2.04-14 <br />needs to be expanded and the data provided in Volume III Tab 6 should be described in <br />the PAP. CAM indicated in the June 20, 2008 response letter to the Division's <br />completeness review that experience at Roadside, Cameo, Munger, and McClane Canyon <br />Mines indicates the Cameo Seam does not have acid-forming properties. Please <br />substantiate this by including a discussion and analysis of the geochemical data presented <br />in Tab 6 sufficient to confirm the statement that the Cameo Seam does not have acid- <br />forming properties. <br />16. On page 2.04-14 CAM references coal seam analytical data obtained from "some historic <br />information from Snowcap Coal Company's permit". Please clarify this statement and if <br />appropriate include a reference to the Roadside Mine and discussion of the chemical <br />analyses presented for the Roadside Mine in Tab 6. Also, the first table presented in Tab <br />6 "Cameo Seam Roof and Floor Analysis" does not indicate where these data were <br />obtained. It appears that they were from drill holes within the Red Cliff permit area. The <br />revised geochemical analyses discussion should clearly identify and reference the <br />tabulated data presented in Tab 6. <br />17. Rule 2.04.6(3)(a)(v) requires a description of the near surface geology beneath areas to be <br />disturbed, including textural analyses and chemical analyses to identify those horizons <br />which contain potential acid-forming, toxic-forming, or alkalinity-producing materials. <br />Excavation associated with coal waste disposal founding, rail loadout/wash plant <br />facilities, and segments of the main haul road and coal mine waste haul road, would to a <br />large extent be in material dominated by Mancos shale. This material would comprise