2011-06-21_APPLICATION CORRESPONDENCE - C2010088

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Corey Heaps CAM Colorado LLC June 21, 2011 Page 41 Division regarding the necessity of obtaining a reclamation permit for the proposed excavation location of material intended to be utilized as fill for the coal loadout facilities. The Division's minerals section determined that the proposed operation would need a reclamation permit. Tavistock challenged the Division's decision and requested a Declaratory Order from the Mined Land Reclamation Board (Board) exempting the proposed operation from the need to obtain a reclamation permit. A declaratory order hearing was scheduled for the November 17, 2010 meeting of the Board. However, Tavistock and the Division mutually agreed to continue this hearing to the December Board meeting to allow for additional research to be conducted into the need for a reclamation permit (Construction Materials, Coal, or a combination) for this borrow site location. On page 2.05 -28 CAM states "Most of the imported fill will be obtained from an adjacent DMRS permitted gravel pit." Please clarify this statement and identify in the application the permitted pit including name, location and DRMS Permit Number. Also please note that DRMS is incorrectly spelled on this page of the application. CAM Response: The revised rail alignment generated approximately 15,000 CY of excess material, and therefore, a coverfill pile has been designed and can be seen on Map -16. Therefore, 70,000 CY is no longer needed for construction of the rail. Division Response: CAM states, in their response that the 70,000 CY is no longer needed and reference to 70,000 cubic yards of fill removed from and adjacent DRMS gravel pit was removed from the permit text. Revised page 2.0530 now states that material may be imported from an adjacent DRMS gravel pit(s) or by rail. This contradicts the above CAM response. Is CAM planning to use the approximate 10.5 acre borrow material site for importing fill material to the Fruit Loadout? There are several implications to the pending coal permit application with the inclusion of the material borrow area (see the Division letter to CAM dated December 7, 2010). Please clarify this discrepancy and modify the permit application accordingly. Also on Map 16 the Coverfill Pile is mislabeled as 15,00 CY. Please correct Map 16. 65a. The second paragraph of (1) on page 2.05 -29 states that the construction material stockpile will not be restored... The use of "stockpile" seems to be erroneous -- please replace with the words "borrow area" if appropriate. Rule 2.05.4(2)(d) Removal, Storage and Redistribution of Topsoil, Subsoil, and Other Material 66. The applicant plans to replace topsoil to an approximate 6" thickness on the areas from which it was salvaged. Narrative in the text section indicates that regraded surfaces will be ripped prior to topsoil replacement, "if necessary to relieve compaction ". Given the heavy textured subsoils and extent of compaction that will occur within the facilities area, ripping will be warranted. Please clarify that "ripping to a minimum 2 foot depth will be employed on regraded surfaces prior to topsoil replacement". CAM Response: Please see revised page 2.05 -30