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Corey Heaps <br />CAM - Colorado, LLC <br />November 30, 2010 <br />Page 6 <br />10. Ground surface elevation information for the monitoring wells does not appear to be <br />consistent between the summary table information on the typical diagram in Exhibit 3 as <br />compared with the As -Built Drawings for the well completions provided in Exhibit 14. <br />Have the wells been re- surveyed by CAM? If so, were the ground surface and top of <br />casing elevations surveyed? Please expand the well completion summary table on the <br />typical diagram to include the following: ground surface elevation, top of casing or <br />measuring point elevation, and perforated interval depth. <br />11. An As -Built Drawing is given for monitoring well RW -5 in Exhibit 14 but it apparently <br />was not included in the proposed monitoring plan and its location is not provided on any <br />other maps or plans. If RW -5 is no longer needed and will not be used in the future then <br />CAM will need to plug and abandon the well and submit the appropriate documentation <br />in accordance with Rule 4.07.3 and submit a well abandonment form to the SEO. If the <br />well will remain open for future use then CAM will need to permit the monitoring well <br />with the SEO, see Item 7 above. <br />12. In the groundwater information section on pages 2.04 -14 &15 there is a discussion of the <br />former Gary Refining Company monitoring wells being utilized for the Fruita Loadout <br />and that groundwater samples were initially analyzed for petroleum hydrocarbons and <br />other compounds. Further, there is a discussion of low -level groundwater contamination <br />(hydrocarbons) detected in samples from two of the four monitoring wells proposed for <br />the site, but there is no mention of the source of the contamination. Although coal <br />operations do not typically produce these types of contaminants clearly documented <br />baseline conditions and future monitoring for any increases in groundwater contaminants <br />will be important. This section should be revised to include background information <br />regarding the likely source for the contamination, describe how baseline conditions have <br />been established, and how future monitoring will be utilized to detect any future increases <br />in groundwater contamination either on -site or migrating on -site. <br />13. Rule 2.04.7(2)(a) requires that the baseline surface water data show seasonal variations in <br />the quantity and quality of the surface water. However, only two quarters of the baseline <br />surface water data are presented in Exhibit 3 of Volume II. Please submit additional <br />baseline surface water data in compliance with Rule 2.04.7(2)(a). <br />14. Under Rule 2.04.7(2)(a) on permit text page 2.04 -18, please expand on the discussion of <br />the Colorado River, including how the river might affect or be affected by the ladout <br />disturbances. <br />15. Under Rule 2.04.7(2)(b), please add the flow data to surface water monitoring station DS- <br />CR in Exhibit 3 of Volume I. <br />