2011-08-08_APPLICATION CORRESPONDENCE - C2010088

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Page 2 of 5 The Division has no further concerns. In the submittal dated April 11, 2011, CAM responded that the adjacent gravel quarry should not be a problem since it is 80 feet higher in elevation than the river and is dry. CAM also responded that the water monitoring sampler will note if the Grand Valley Canal is flowing. In the July 8, 2011 submittal, the hydrologic monitoring program was clarified to show that the Colorado River was not part of the quarterly water monitoring program, just for baseline and for pre -bond release data gathering. 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. In the April 11, 2011 submittal, CAM revised the sediment control system for the railroad loop. However, with the addition of a construction material borrow area, adjacent topsoil stockpile and the unsuitable subgrade storage area adjacent to the rail loop, that portion of the rail loop adjacent to the borrow area would, then, 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. However, a recent proposed change would eliminate the borrow area, borrow area topsoil stockpile and pond 4 from the plan so that portion of the rail loop adjacent to the deleted borrow area can again be considered a haul road not in the disturbed area, with the appropriate non -pond sediment control measures employed. In the July 8, 2011 submittal, Cam provided new hydrology designs and revised maps. In addition, the Division understands that the borrow area will be deleted from consideration. The Division has the following additional requests: 1) Please provide revised permit text, maps and hydrology designs that take into account that the borrow area, borrow area topsoil stockpile and pond 4 will be deleted from the Fruita Loadout plan, that there will be three sediment ponds and that sediment control for the portion of the railroad loop adjacent to the deleted borrow area will not involve a sediment pond. 2) In the July 8, 2011 submittal, a new topsoil stockpile, topsoil pile #3, was added along the railroad spur line. Since this topsoil stockpile does not drain to a sediment pond, the stockpile needs to be designed as a small area exemption (SAE). Please provide the appropriate hydrology designs for the topsoil stockpile SAE, describe the topsoil stockpile SAE in the appropriate permit text sections and add the SAE designation to the appropriate maps.