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Corey Heaps <br />CAM Colorado LLC <br />August 10, 2011 Page 8 <br />Rule 2.05.3 Operation Plan — Permit Area <br />44 -45. Items resolved. <br />Rule 2.053(3) Mine Facilities <br />46. Item resolved. <br />47. Under Rule 2.05.3(3)(c) and referring to Map 16, "Loadout Facilities ", please explain <br />why CAM has elected to make the entire railroad loop drainage report to sediment ponds. <br />It appears to the Division that the portion of the railroad loop not adjacent to the loadout <br />facilities disturbance could be considered as a haul road not in the disturbed area as <br />defined in Rule 4.05.2(4) and, therefore, falls under Rule 4.03.1(4)(iv), similar to the <br />situation with the railroad spur. If changes are made to the sediment control system, <br />please revise the discussions concerning the sediment control system found throughout <br />the permit application. <br />In the April 11, 2011 submittal, CAM revised the sediment control system for the railroad loop. <br />However, with the addition of a construction material borrow area, adjacent topsoil stockpile and <br />the unsuitable subgrade storage area adjacent to the rail loop, that portion of the rail loop adjacent <br />to the borrow area would, then, be considered a haul road within the disturbed area and, as <br />required under Rule 4.03.1(4) (a) (iii) and Rule 4.05.2, be required to pass the disturbed area <br />runoff through a sedimentation pond or other treatment facility. However, a recent proposed <br />change would eliminate the borrow area, borrow area topsoil stockpile and pond 4 from the plan <br />so that portion of the rail loop adjacent to the deleted borrow area can again be considered a haul <br />road not in the disturbed area, with the appropriate non -pond sediment control measures <br />employed. <br />In the July 8, 2011 submittal, Cam provided new hydrology designs and revised maps. In <br />addition, the Division understands that the borrow area will be deleted from consideration. The <br />Division has the following additional requests: <br />1) Please provide revised permit text, maps and hydrology designs that take into <br />account that the borrow area, borrow area topsoil stockpile and pond 4 will be <br />deleted from the Fruita Loadout plan, that there will be three sediment ponds <br />and that sediment control for the portion of the railroad Ioop adjacent to the <br />deleted borrow area will not involve a sediment pond. <br />2) In the July 8, 2011 submittal, a new topsoil stockpile, topsoil pile #3, was added <br />along the railroad spur line. Since this topsoil stockpile does not drain to a <br />sediment pond, the stockpile needs to be designed as a small area exemption <br />(SAE). Please provide the appropriate hydrology designs for the topsoil stockpile <br />SAE, describe the topsoil stockpile SAE in the appropriate permit text sections <br />and add the SAE designation to the appropriate maps. <br />3) It appears that Figure 13 should be re- labeled as Map 13. <br />