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Corey Heaps <br />CAM Colorado LLC <br />June 21, 2011 Page 16 <br />CAM Response: Map unit and interpretations would not be different if the soils report <br />used the Web Soil Survey. Results for the salvage plan were based on actual samples, not <br />based on a soil type listed on a map. Pages 8 & 9 of the soils report were inadvertently not <br />included in Exhibit 7. Please insert pages 8 & 9 into Exhibit 7. Page 8 should answer the <br />questions listed in number. 23 above. <br />Division Response: Response accepted. <br />24. A significant portion of the area to be affected has been previously disturbed by Industrial <br />activity, and the surface materials present in these areas are dominated by industrial wastes <br />that are essentially barren of vegetation. There are generalized references to possible <br />importation of cover material from outside the permit area to serve as a growth medium <br />within the previously disturbed areas, since the surface materials within the areas of <br />previous disturbance support little or no vegetative growth. Although given the <br />circumstances, the imported material would not meet the specific regulatory definition of <br />topsoil substitute, at least a portion of the material would function as such (additional <br />material placed over the industrial waste and beneath the surface growth medium would <br />function as subsoil, or non -toxic cover). Detailed plans regarding the source, quantity, and <br />replacement thickness of proposed topsoil and non -toxic cover soil will need to be <br />provided, along with the information required by Rule 4.06.2(a), to demonstrate the <br />acceptable quality of such material as a plant growth medium. Plans for storage and <br />stabilization of such materials on the permit area will also need to be included. Please <br />address the use of imported topsoil and cover material for use in reclamation of the <br />previously disturbed industrial land use areas, pursuant to Rule 2.04.9(3). <br />CAM Response: Additional soil sampling is planned around site #1 in order to determine <br />if additional material can be salvaged and used for topsoil replacement. After testing is <br />complete, CAM will prepare a salvage plan for incorporation into the permit. <br />Division Response: This item has not been resolved. CAM is doing additional soil <br />sampling around site #1 to determine if additional material can be salvaged and used for <br />topsoil replacement. The Division will not comment further on this issue until CAM <br />submits a topsoil salvage plan based on the new soil data. <br />24a. A site and profile description for soil sample TSO -4 is not included in Exhibit 7. <br />Please add a description of soil sample TSO -4 to the permit along with an explanation <br />of why the sample was taken at a different time and why only the top 36 inches were <br />sampled instead of 72 inches like the other three samples. <br />24b. In the area west of Reed Wash, the upper 6 inches of topsoil is proposed to be <br />salvaged on 4.8 acres of the railroad bed corridor. According to Map 16, Loadout <br />Facilities, two topsoil stock piles are east of Reed Wash. It is unclear in the text and <br />on the maps, how equipment will access the area west of Reed Wash to transport the <br />salvaged topsoil to the stock piles. Please include a plan in the permit showing access <br />