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

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Corey Heaps CAM - Colorado, LLC November 30, 2010 Page 20 Rule 2.05.4(2 (f) Disposal. of Debris, Acid Forming and Toxic Forming Materials 77. Narrative in this section states that there is no indication that any acid forming or toxic forming materials will be encountered on site. While data in Tab 6 appear to confirm the absence of acid forming materials, the absence of toxic forming materials is not supported, and the narrative will need to be revised. "Toxic Forming Materials" is defined in Rule 1.04 (139) as "...earth materials or wastes which, if acted upon by air, water, weathering, or microbiological processes, are likely to produce chemical or physical conditions in soils or water that are detrimental to biota or uses of water ". Given the fact, as noted in Section 2.04.3, that the surface materials within the land farm evaporation ponds "appear to be sterile since they are completely devoid of vegetation ", there is an indication of the presence of toxic forming materials. In addition to the evaporation ponds with exposed industrial waste, there are several locations where buried coke fines would be impacted by site development. Test pit sample data in the Tab 6 "Unit Train Loadout Samples" table indicate elevated levels of numerous parameters, including boron, selenium, iron, manganese, mercury, and zinc, and various other parameters, including high level of total combustible solids in the boiler blowdown material. Please include discussion of the sample results obtained, and interpretation of the results with respect to potential for impacts to plant growth and food chain impacts. Based on consideration of the sample results, address planned measures for handling, and temporary stabilization of the industrial waste materials during site development and operations, as well as final reclamation or disposal of the industrial waste materials that will be disturbed. If grading, placement of a soil cover, and revegetation is planned, as discussed in generalities in Section 2.05.6(2)(a)(ii), and various other sections, please provide detailed plans regarding cover soil source, quality, and thickness, along with revegetation plan and seedmix appropriate for the soil characteristics and site objectives. The Division will likely require that a minimum 4 foot thickness of non toxic cover material be placed over the industrial waste materials unless it can be demonstrated that an effective vegetation cover can be safely and effectively established over the materials with a lesser cover thickness. 78. Please address plans for cleanup and disposal of ditch and pond cleanings and coal fines during operational maintenance and as a component of the final reclamation plan. 79. There is a minor error regarding the reference in the first paragraph of the section on page 2.05 -37 to Section 2.04.6(a)(iii)(D). The correct reference would appear to be 2.04.6(3)(a)(v)(B). Note that the paren (v) notation on page 2.04 -11 appears to have been erroneously omitted, and needs to be inserted. Please amend the text as appropriate. Rule 2.05.4(2)(h) Other Permits 80. This requirement needs to be addressed in the PAP at the bottom of page 2.05 -38. Please add a reference here to the locations of approved permits or applications for permit(s)