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However, there does not appear to be a map that shows who these landowners are. Map 02, <br />"Surface Ownership", does not show sufficient aerial extent to the west and north. Please revise <br />Map 02 to show all relevant surface water users. <br />8. Under Rule 2.05.3(3)(c) and referring to Map 16, "Loadout Facilities", please explain why <br />CAM has elected to make the entire railroad loop drainage report to sediment ponds. It appears <br />to the Division that the portion of the railroad loop not adjacent to the loadout facilities <br />disturbance could be considered as a haul road not in the disturbed area as defined in Rule <br />4.05.2(4) and, therefore, falls under Rule 4.03.1(4)(iv), similar to the situation with the railroad <br />spur. If changes are made to the sediment control system, please revise the discussions <br />concerning the sediment control system found throughout the permit application. Also, the <br />Division has not completed its review of all of the Sedcad designs in anticipation of these <br />changes to the sediment control system. 1? <br />9. On permit text page 2.05-11 in Section 2.05.3(3)(c), it is stated that haul road no. 1 is not <br />within the disturbed area. This is in compliance with Rules 4.05.2(4) and 4.03.1(4)(a)(iv). As <br />such, only best management practices are required for sediment control for haul road no. 1. <br />However, there are four Sedcad hydrology designs for the silt fence along haul road no. 1 that <br />are presented in Exhibit 9 of Volume II. These four designs are not needed and they can be <br />omitted if CAM wishes. <br />10. Please provide a more detailed description in Section 2.05.3(3)(c) on permit text page 2.05-9 <br />and in Section 2.05.6(2)(a)(i) on permit text page 2.05-43 that describes the sediment control <br />and coal spillage control that will be utilized in the construction and operational use of the Reed <br />Wash bridge. <br />11. Under Rule 2.05.3(4), in the Sedcad designs, CAM is using 1.4 inches, 1.8 inches and 2.2 <br />inches as the design precipitation events for the 10 yr 24 hour event, 25 year 24 hour event and <br />100 year 24 hour event respectively. However, referring to the NOAA Atlas 2 "Precipitation- <br />Frequency Atlas of the Western United States", the Division obtained values of 1.6 inches, 2.0 <br />inches and 2.6 inches respectively. It appears that CAM may have used the NOAA May to <br />October precipitation event figures rather than the NOAA annual precipitation event figures. <br />Please justify the precipitation event values used in the Sedcad designs or revise the Sedcad <br />designs accordingly. <br />12. Under Rule 2.05.3(4), in the Sedcad designs for the west culverts, a curve number of zero is <br />used for the irrigated wetlands rea, citing a ground cover of 100% as justification for that curve <br />number. If the wetlands are saturated or are comprised of standing water, a precipitation event <br />could produce runoff, in spite of the vegetative cover. Please describe the nature of the <br />wetlands as it relates to the determination of the curve number. <br />13. Please add a more detailed description in Section 2.05.3(4)(a)(ii)(C) on permit text 2.05-18 and <br />in the Probable Hydrologic Consequences Section 2.05.6(3)(b)(iii) starting on permit text page <br />2.05-49 for the process of dewatering the sediment ponds, including how Reed Wash will be <br />protected from erosion and siltation from disposal of the pond water. <br />2