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Page 3 of 6 <br />facilities disturbance could be considered as a haul road not in the disturbed area as defined in <br />Rule 4.05.2(4) and, therefore, falls under Rule 4.03.1(4)(iv), similar to the situation with the <br />railroad 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. <br />In the April 11, 2011 submittal, CAM revised the sediment control system for the railroad loop. <br />However, because the newly proposed construction material borrow area, adjacent topsoil <br />stockpile and the unsuitable subgrade storage area will be located adjacent to the rail loop, that <br />portion of the rail loop would now be considered a haul road within the disturbed area and, as <br />required under Rule 4.03.1(4)(a)(iii) and Rule 4.05.2, be required to pass the disturbed area <br />runoff through a sedimentation pond or other treatment facility. <br />Since these three areas appear to be too large in aerial extent to qualify as small area <br />exemptions, it would appear that designed drainage ditches and a new or enlarged pond would <br />be necessary. Please provide a revised sediment control plan for the southern section of the <br />railroad loop. <br />As a related matter, CAM states on revised page 2.05-21 of the April 11, 2011 submittal that <br />the borrow area will serve to contain the disturbed area runoff since it will be a pit. However, <br />the proposed borrow area pit must be considered an impoundment, subject to the requirements <br />of Rules 4.05.6 and 4.05.9 and no such sediment pond designs were submitted. Please address <br />the impoundment issue in regard to the construction material borrow area. <br />48. On permit text page 2.05-I1 in Section 2.05.3(3)(c), it is stated that haul road no. I 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 />In the April 11, 2011 submittal, CAM elected to remove the four silt fence designs for haul <br />road no. 1 from Exhibit 9. However, the Division requests that the ditch representation on Map <br />16 that runs along haul road no. 1 be removed, leaving only the berm representation and the silt <br />fence representation. <br />49. 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 <br />Reed Wash bridge. <br />The Division has no further concerns. Permit text pages 2.05-9 and 2.05-45 were revised in the <br />April 11, 2011 submittal to include a discussion of the sediment and coal spillage control <br />measures.