2008-08-29_APPLICATION CORRESPONDENCE - C2008086

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