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Mike Boulay -39- April 11, 2011 <br />be minimized). Further, include narrative addressing compliance with the <br />various requirements listed under 4.18(5), and reference application sections <br />or maps where relevant details are provided. Specifically address the <br />potential that sediment ponds could present a wildlife hazard due to the <br />industrial wastes present on site, and identify protective measures that <br />would be employed if warranted. <br />CAM: Text regarding raptor protection and stream buffer zones has been included on <br />page 2.05-44. There will not be any special protective measures employed to deal <br />with the sediment ponds due to the perceived risks associated with industrial <br />wastes on site. This area received Closure Certification from CDPHE on August <br />25, 2005 for residential/unrestricted use (Exhibit 15). If the CDPHE has approved <br />the area for residential use, the operator believes wildlife will be safe from any <br />perceived risk due to the industrial waste located on site. <br />88. In Subsection (2)(a)(111) please specifically describe and provide design <br />details for silt fence or measures to be maintained along the toe of the rail <br />spur fill that comes into contact with the irrigated wetlands west of Reed <br />Wash. can design after rail spur design is complete <br />CAM: Please see revised page 2.05-45 to 46 and new silt fence designs, SF-1 through <br />SF-8, shown in Exhibit 9 on pages Exh. 9-35 through 50. <br />Rule 2.05.6(3) Protection of Hydrological Balance <br />89. In the Probable Hydrologic Consequences (PHC) discussion of Subsection (b)(iii) <br />there is no discussion of the potential for leachate entering into the shallow alluvial <br />groundwater from the sediment ponds. As discussed earlier in this letter there is a <br />very good possibility that leachate from the ponds would discharge directly to <br />groundwater since pond bottom elevations are very close to the groundwater table. <br />Please add an additional analysis here that accounts for the leachate from <br />the sediment ponds that may enter into the groundwater, and potentially <br />into Reed Wash. It may be appropriate to combine the sediment pond <br />discharges to the leachate from the coal pile and calculate a weighted <br />average for the combined leachate. <br />CAM : The Operator does not believe leachate will enter the groundwater. <br />Please see discussion on page 2.05-51. <br />90. On page 2.05-51 potential impacts to groundwater are described. For ease of <br />comparison please add a table that shows leachate data compared to <br />groundwater data from well RW-1. <br />CAM: A column for RW-1 has been added to the existing table and page 2.05-51, and <br />the existing table on page 2.05-52.