2009-08-28_REVISION - C1981041 (3)

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J. E. STOVER & ASSOCIATES, INC. 2352 NORTH 7th SREET, UNIT B GRAND JUNCTION, COLORADO 81501 PHONE: (970) 245-4101, FAX 242-7908 MINE ENGINEERING MINE RECLAMATION August 26, 2009 Mike Boulay Division of Reclamation, Mining & Safety 101 South 3`d, Suite 301 Grand Junction, CO 81501 Re: Snowcap Coal Company, Inc. Technical Revision No. 59 (TR-59) Adequacy Review Comments Permit No. C-81-041 Dear Mr. Boulay: RECEIVED AUG 2 8 2009 Division v, n-,c,amati®n, Mining and Safety CIVIL ENGINEERING CONST. MANAGEMENT The DRMS' letter dated July 6, 2009 transmitted its adequacy comments regarding TR- 59. Following are Snowcap's responses to the DRMS' comments and concerns: 1. DRMS: Please describe in the permit application the process for permitting the recently identified jurisdictional wetland areas and specifically address how Condition 12 of the Mesa County Conditional Use Permit for the Halliburton-Cameo Sand Storage Facility is being met. Condition 12 requires that all necessary clearances and permits be obtained from the U.S. Army Corps of Engineers. Please add a discussion regarding the jurisdictional wetlands and whether or not a Section 404 permit is required. On page 14- 91, SCC states that the flat gradient of the drainage swale connecting ponds 1 and 2 and associated slow velocity will allow solids to settle thus virtually eliminating the discharge of sediment in to the wetland(s). If this precludes the need for a Section 404 permit, then this should be clearly stated in the revised text. The wetland areas are shown on Exhibit 10C and 11 C these locations should also be referenced in the amended text. If a Section 404 permit is required then it should be listed in the permit application package in accordance with Rule 2.03.10. SCC: All jurisdictional wetlands within the Conditional Use Permit area have been delineated by WestWater Engineering and approved by the U.S. Corp of Engineers. Halliburton's Site Plan submitted to the county shows that the jurisdictional wetlands will not be affected by the Sand Storage Facility project, therefore no clearances or permits will be required from the Corp of Engineers. These actions show that Condition 12 has been met. Enclosed are new appendix pages A15-2-28 through A15-2-30, the US Army Corp of Engineer's letter and drawing that approve the wetland delineation, and revised permit page 14-9i stating that a Section 404 permit is not required. 2. DRMS: The potential for sediment deposition to the wetland areas is described in the revised text, but there is no mention of water quality impacts, if any, to the wetland areas. Please add a discussion of any discharges to the wetlands from the proposed