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C- 2010 -088 Fruita Loadout <br />3rd Preliminary Adequacy Review (MLT) <br />20- Jul -2011 <br />Page 3 of 10 <br />second paragraph of Section 2.05.3(c) and on Map 15, Haul Road #l, which is 0.58 miles <br />in length, is described as having a minimum width of 12 feet. It appears that the road is <br />intended to function as a two -way road, carrying all traffic entering and exiting the <br />Loadout facility, including highway -legal coal haul trucks. The proposed narrow width <br />of Haul Road #1 is insufficient to allow for two -way traffic. Please revise the width to an <br />appropriate dimension which will allow traffic moving in opposing directions to pass <br />safely. The local governing agency, i.e. Mesa County or the City of Fruita, likely has <br />minimum width requirements for two -way roads. <br />The minimum width for Haul Road #1 has been increased to 20 feet in the text of Section <br />2.05.3(3)(c) and in the dimension label on the Map 15 typical section. In response to this <br />item, the applicant also explains that CAM has only a 30 foot easement for accessing the <br />site, and since sediment control must be included, the roadway width must be limited at <br />20 feet. <br />Based on information presented in the APEN in Exhibit 11, full utilization of the loadout <br />(1, 000, 000 tons of coal per year) will result in 160 haul trucks per day using Haul Road <br />#1 to access the loadout and return to 15 Road. At 20 hours per week, this results in an <br />average of 40 trucks per hour making the round trip. <br />Semi tractor - trailer rigs are typically 8.5 feet wide. Two trailers passing one another <br />will therefore use up 17 feet of space. The remaining 3 feet (of a 20 foot roadway) are <br />insufficient to allow both far space between the vehicles and clearance at the roadway's <br />edge. Vehicular safety must be the first priority in the design of any roadway. If the <br />possibility exists, as stated on page 2.05 -13, that the City ofFruita may annex Haul Road <br />#1, it may be prudent to design the road to meet City standards. <br />The Division notes that two separate 30' easements are addressed in the `Easement and <br />Reaffirmation Agreement "found in Exhibit 1: a Central Easement and a South <br />Easement. If two -way traffic cannot be safely accommodated within one easement, does <br />the potential exist for one -way in and one -way out using both easements? <br />Please revise the design for Haul Road #1 to comply with the requirements of <br />4.03.1(3) (c). <br />CAM has revised the driving surface of Haul Road #1 to be 25 feet wide, as shown on <br />Map 15. The road continues to occupy the 30 foot "Central Easement" described in <br />Exhibit 1. <br />With respect to sediment control, the typical section on Map 15 shows the roadway <br />surface having a 2% cross slope to the south, 2H.-I V side slopes, and a berm with 2H:1 V <br />slopes on the south side of the road. The height of the roadway embankment and the <br />height of the berm are not shown. The Division suggests that given the flat nature of the <br />roadway profile and the ground surface, and the limited space available, other BMPs, <br />e.g. silt fence or excelsior logs, might be preferable to construction of a bermed ditch. <br />Due to the limited easement width, CAM has modified the design of Haul Road #1 (on <br />Map 15 and page 2.0512) to incorporate excelsior logs for sediment control. <br />