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

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Corey Heaps CAM - Colorado, LLC November 30,20 10 Page 21 demonstrating compliance with all other applicable air and water quality laws and regulations and health and safety standards. The Division understands that CAM has applied for the appropriate permit from the Army Corps of Engineers for the wetland disturbances and for an NPDES permit will provide copies to the Division for insertion into the PAP when the permits are obtained. Rule 2.05.5 Postmining Land Uses 81. Please refer to Item 3 of this letter, under "Site Description and Land Use Information" regarding requested map and narrative clarifications pertinent to both premining and postmining land uses. Provision of separate premining and postmining maps may be warranted for clarification, as noted in Item 3. 82. In section 2.04.3(2)(b), narrative states that "the barren lands east of Reed Wash are limited to some future industrial use ", and narrative in Section 2.05.5(2)(a)(iii) states that industrial use is considered to be the highest and best use of the lands to be reclaimed to the east of Reed Wash. Please include further discussion pursuant to 2.05.5(2)(a), addressing the utility and capacity of the lands east of Reed Wash within the permit area, and why a future industrial use is the highest and best use of the lands. Consider revision of the "Industrial" land use boundary to coincide with the Previously Disturbed Lands perimeter, or provide justification for designation of Reed Wash as the boundary between "Industrial" and "Fish and Wildlife Habitat" land use areas. 83. The type of support activities that would be needed to achieve the industrial land use are not addressed, beyond the statement that the use would be achieved by reclaiming the disturbed area in accordance with Section 2.05.4. The fact is that unless/until a specific postmine industrial use for the site is determined, details regarding necessary support measures cannot be known. However, at present, reclamation of the site to support a future industrial use would entail facilities removal, site grading, burial or coverage of exposed industrial wastes, and establishment of a stabilizing vegetation cover. Please include explanation using Ianguage similar to the above, within the narrative of Section 2.05.5. Rule 2.05.6(1) Air Pollution Control Plan 84. On page 2.05 -43 there is an incorrect reference to the location of the air emission permit application. It should be Volume I, Tab 11 not Tab 10. Rule 2.05.6 (2) Fish and Wildlife Plan 85. In Subsection (2)(a)(i), the applicant commits to using best management practices for watershed protection during construction activities. Presumably, those activities would relate to the installation of both short term and long term drainage and sediment control, and soil stabilization measures, in both the primary facilities area and along roads and the