2010-11-30_APPLICATION CORRESPONDENCE - C2010088 (2)

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Corey Heaps CAM - Colorado, LLC November 30, 2010 Page 15 50. Since there are several locations where the railroad spur and loop are close to Reed Wash, the Division suggests that a barrier, such as a berm, be constructed between the railroad tracks and Reed Wash in case of a coal spill from the railcars. 51. The plan and profile of the proposed rail loop is provided on Map 21; there is very little other information presented within the application. Based on communication with Ms. Stover - Bishop, Union Pacific railroad has its own detailed requirements governing the construction of embankments. Please provide a summary of those requirements for inclusion within the permit text. Otherwise, the Division will need to require that the embankments be constructed in accordance with the Rules for roads and embankments. Rule 2.05.3(3)(c)(i) requires that specifications for each bridge be provided. On page 2.05- 9, the bridge is described as being 9' in width and 60' in length, constructed of steel girders with concrete abutments. The second paragraph states that geotechnical work on the foundation will be performed prior to construction of the bridge. Please provide general details and a plan sheet of the proposed bridge for inclusion in the permit application. Rule 2.05.3 0) Ponds Impoundments, and Diversions 52. The Division is concerned that groundwater may be exposed during the construction of at least two of the five proposed sediment ponds. Ponds 2 and 4 have bottom elevations that are very close to the groundwater table. For example, using the minimum groundwater elevations (worse case or highest level) reported for Pond 4 in Exhibit 3 and extrapolating these numbers between the wells, the Division estimates the groundwater elevation to be about at 4449.3' at Pond 4. The bottom of the Pond 4 as shown on Map 14 is 4450'. This appears to be essentially the same elevation as the water table at this location. Likewise Pond 2 bottom elevation would be within about three feet of the ground water table at the proposed location for the pond. The Division of Water Resources has raised this same concern (see Item 7 of this letter). If the construction of any sediment ponds exposes groundwater, the pond must be backfilled immediately until a well permit is obtained from the State Engineer. If a well permit is obtained for these ponds another potential concern is that when these ponds are full they would likely discharge through the bottom of the pond directly to groundwater. Unlined pits discharging to groundwater may require authorization from the Colorado Department of Public Health and Environment, Water Quality Control Division and a CDPS discharge permit may be necessary. One option would be to line the ponds but this is not discussed and there are no plans presented for pond liners. Given the fact that pond bottom elevations are very close to the groundwater table, the Division is requesting that the plan designs and discussion for each of the ponds be reviewed and revised accordingly. PIease elaborate on whether or not groundwater is likely to be encountered at each pond location and provide appropriate mitigation plans. Otherwise show that the appropriate permits have been obtained for exposing groundwater from the Division of Water