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C- 2010 -088 Fruita Loadout <br />2 d Preliminary Adequacy Review (MLT) <br />25- May -2011 <br />Page 4 of 8 <br />other BMPs, e.g. silt fence or excelsior logs, might be preferable to construction of a <br />bermed ditch. <br />10(118) Page 2.05 -10 describes the proposed methods of haul road construction. What is the <br />type of borrow material to be used to construct embankments? The proposed lift <br />thicknesses of 12" may be too great to achieve the desired compaction, unless the <br />material includes a high percentage of cobble -sized material. AASHTO T99 is <br />appropriate for use with fine - grained soils. However, for road base surfacing, T180 is the <br />preferred method. <br />Certain additional details were incorporated with the Apr -2011 response, but a number <br />of questions remain regarding design and construction of the haul roads. These <br />questions are itemized elsewhere in this adequacy review. <br />Miscellaneous Corrections <br />11(43) Please change the word "aerial" to "areal" in section 2.05.2(2) and in the Clean Coal <br />Storage Pile paragraph on page 2.05 -6. <br />The correction was made at both locations. Item resolved <br />12(44) Page 2.05 -3 — the section title, "205.3 Operation Plan — Permit Area" is missing from this <br />page. <br />The requested title was added Item resolved <br />13(45) Page 2.05 -4 — please delete "Underground Mining" from the title of (2) <br />The text was deleted, as requested Item resolved <br />NEW ITEMS <br />I have compiled a new series of adequacy issues, detailed on the following pages. They are <br />organized by permit section / rule, to aid in your incorporating them into the formal Adequacy <br />Response #2. Please advise me if another format would be more helpful to you. <br />2.03 Right of Entry <br />• In 2.03.6, a general description of the proposed permit boundary is provided. Please provide <br />the total acreage of the proposed permit area. <br />• The permit boundary was modified for the Apr -2011 response to include the Construction <br />Material Borrow Area, located on land owned by Tavistock. Does CAM have a lease for this <br />parcel? Please include any lease in Exhibit 1. <br />• It appears that the western boundary of the permit was also adjusted with the Apr -2011 <br />response. In CAM's next response letter, please address any changes to the original <br />