2011-07-11_APPLICATION CORRESPONDENCE - C2010088

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Mike Boulay Rule 2.05.3(3) Mine Facilities 46. Division Response: Response accepted. -18- July 8, 2011 47. Under Rule 2.05.3(3)(c) and referring to Map 16, "Loadout Facilities ", please explain why CAM has elected to make the entire railroad loop drainage report to sediment ponds. It appears to the Division that the portion of the railroad loop not adjacent to the loadout facilities disturbance could be considered as a haul road not in the disturbed area as defined in Rule 4.05.2(4) and, therefore, falls under Rule 4.03.1(4)(iv), similar to the situation with the railroad spur. If changes are made to the sediment control system, please revise the discussions concerning the sediment control system found throughout the permit application. CAM Response: Sections 2.05.3(4), 2.05.6(2) and 2.05.6(3) have been revised. Division Response: In the April 11, 2011 submittal, CAM revised the sediment control system for the railroad loop. However, because the newly proposed construction material borrow area, adjacent topsoil stockpile and the unsuitable subgrade storage area will be located adjacent to the rail loop, that portion of the rail loop would now be considered a haul road within the disturbed area and, as required under Rule 4.03.1(4)(a)(iii) and Rule 4.05.2, be required to pass the disturbed area runoff through a sedimentation pond or other treatment facility. Since these three areas appear to be too large in aerial extent to qualify as small area exemptions, it would appear that designed drainage ditches and a new or enlarged pond would be necessary. Please provide a revised sediment control plan for the southern section of the railroad loop. As a related matter, CAM states on revised page 2.05 -21 of the April 11, 2011 submittal that the borrow area will serve to contain the disturbed area runoff since it will be a pit. However, the proposed borrow area pit must be considered an impoundment, subject to the requirements of Rules 4.05.6 and 4.05.9 and no such sediment pond designs were submitted. Please address the impoundment issue in regard to the construction material borrow area. CAM - Please see revised Map -13 showing newly designed sediment ponds 3 & 4. In addition, please see new SedCad designs for ponds 3 & 4 as shown on pages EXH. 9 -35 -52 of Appendix 9. Sediment Pond #3 will contain flow from the unsuitable materials storage area. Sediment Pond #4 will contain flow from the construction materials borrow area. There are no ditches associated with Pond #4, therefore, the SedCad sheets do not include a 10 -year event evaluation, as the pond is sized to contain the 25 -year event. Please see revised text pages 2.05 -17- 22. Please see revised ditch and culvert summary table, page EXH 9 -2. Although the design for pond #2 did not change, for simplicity, the entire Appendix 9 will be submitted for review due to the changes to the page numbering.