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

Home Browse Search

Corey Heaps CAM - Colorado, LLC November 30, 2010 Page 22 rail spur. Please summarize the practices that will be employed, and reference the relevant application sections where such practices are addressed in more detail. In the same subsection, water depletions and associated measures are referenced. A sentence fragment related to the water depletion discussion is missing, between the bottom of page 2.05 -43 and top of page 2.05 -44. Please restore the missing sentence fragment. 86. Please expand the discussion under Subsection (2)(a)(ii) regarding impact minimization/habitat enhancement. Specific details will need to be included within the appropriate sections of the application (and referenced in (2)(a)(ii)), regarding measures that will be employed to establish vegetation cover on the 23.6 acres of essentially barren land dominated by exposed and buried industrial wastes. Please summarize the practices that will be employed (e.g. soil importation and/or burial of exposed wastes, seeding practices and seed mix, success standards, etc.), and reference the relevant application sections where such practices are addressed in more detail. 87. Please expand the narrative under (a)(ii), to address compliance with the requirements of Rule 4.18 (4) for powerline construction (provide construction design that will ensure that electrocution hazard to raptors will be minimized). Further, include narrative addressing compliance with the various requirements listed under 4.18(5), and reference application sections or maps where relevant details are provided. Specifically address the potential that sediment ponds could present a wildlife hazard due to the industrial wastes present on site, and identify protective measures that would be employed if warranted. 88. In Subsection (2)(a)(iii) please specifically describe and provide design details for silt fence or measures to be maintained along the toe of the rail spur fill that comes into contact with the irrigated wetlands west of Reed Wash. Rule 2.05.6(3) Protection of Hydrological Balance 89. In the Probable Hydrologic Consequences (PHC) discussion of Subsection (b)(iii) there is no discussion of the potential for leachate entering into the shallow alluvial groundwater from the sediment ponds. As discussed earlier in this letter there is a very good possibility that leachate from the ponds would discharge directly to groundwater since pond bottom elevations are very close to the groundwater table. Please add an additional analysis here that accounts for the leachate from the sediment ponds that may enter into the groundwater, and potentially into Reed Wash. It may be appropriate to combine the sediment pond discharges to the leachate from the coal pile and calculate a weighted average for the combined leachate. 90. On page 2.05.51 potential impacts to groundwater are described. For case of comparison please add a table that shows leachate data compared to groundwater data from well RW -1.