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Corey Heaps <br />CAM Colorado LLC <br />June 21, 2011 <br />Page 45 <br />or microbiological processes, are likely to produce chemical or physical conditions in soils <br />or water that are detrimental to biota or uses of water ". Given the fact, as noted in Section <br />2.04.3, that the surface materials within the land farm evaporation ponds "appear to be <br />sterile since they are completely devoid of vegetation ", there is an indication of the <br />presence of toxic forming materials. In.addition to the evaporation ponds with exposed <br />industrial waste, there are several locations where buried coke fines would be impacted by <br />site development. Test pit sample data in the Tab 6 "Unit Train Loadout Samples" table <br />indicate elevated levels of numerous parameters, including boron, selenium, iron, <br />manganese, mercury, and zinc, and various other parameters, including high level of total <br />combustible solids in the boiler blowdown material. Please include discussion of the <br />sample results obtained, and interpretation of the results with respect to potential for <br />impacts to plant growth and food chain impacts. Based on consideration of the sample <br />results, address planned measures for handling, and temporary stabilization of the industrial <br />waste materials during site development and operations, as well as final reclamation or <br />disposal of the industrial waste materials that will be disturbed. If grading, placement of a <br />soil cover, and revegetation is planned, as discussed in generalities in Section <br />2.05.6(2)(a)(ii), and various other sections, please provide detailed plans regarding cover <br />soil source, quality, and thickness, along with revegetation plan and seedmix appropriate <br />for the soil characteristics and site objectives. The Division will likely require that a <br />minimum 4 foot thickness of non toxic cover material be placed over the industrial waste <br />materials unless it can be demonstrated that an effective vegetation cover can be safely and <br />effectively established over the materials with a lesser cover thickness. <br />CAM Response: There is no indication that any acid - forming or toxic forming materials <br />will be encountered on site. Please refer to section 2.04.6(3)(a)(v)(B). <br />Division Response: Response accepted. <br />78. Please address plans for cleanup and disposal of ditch and pond cleanings and coal fines <br />during operational maintenance and as a component of the final reclamation plan. <br />CAMResponse: Pond and ditch cleanings will be hauled back to the McClane Canyon <br />mine and either placed in the sediment drying location, or the approved Coal Mine Waste <br />Disposal area. Please see revised page 2.05 -27. <br />Division Response: Response accepted. <br />79. There is a minor error regarding the reference in the first paragraph of the section on page <br />2.05 -37 to Section 2.04.6(a)(iii)(D). The correct reference would appear to be <br />2.04.6(3)(a)(v)(B). Note that the paren (v) notation on page 2.04 -11 appears to have been <br />erroneously omitted, and needs to be inserted. Please amend the text as appropriate. <br />CAM Response: Please see revised pages 2.04 -11 and 2.05 -37. <br />