2012-01-13_APPLICATION CORRESPONDENCE - C2010088 (2)

Home Browse Search

Corey Heaps CAM Colorado LLC January 13, 2012 Page 2 4. Please ensure that the conservation measures listed on page 2.05 -48 are also listed verbatim and are consistent with those listed on page 2.04 -37. 5. CAM has chosen to withdraw the pending Colorado Discharge Permit System (CDPS) Industrial Discharge Permit application following discussions with the Water Quality Control Division. Please ensure that all references and text pertaining to the CDPS Industrial Discharge Permit are removed from the PAP. 6. CAM has been issued a CDPS General Permit for Stormwater Discharges Associated with Light Industrial Activity and this is adequate to cover all stormwater related discharges during operations. This permit has been included in the PAP in Exhibit 13 Other Permits. CAM will still have to apply for a CDPS Stormwater Construction Permit prior to commencing any construction activity or disturbance at the Fruita Loadout Facility. Please keep the Division informed of the application status for this permit. 7. On page 2.05 -20 of the revised text, CAM states that "Sediment removed from the sediment ponds will be hauled back to the McClane Canyon Mine and either stored in their sediment drying are or an approved Coal Mine Waste Disposal area." Please remove this statement and replace with: "Sediment removed from the ponds will be disposed of at an approved disposal facility." 8. The liner information including design and maintenance needs to be included in the detailed design plan for each pond structure in accordance with Rule 2.05.3(4) (a)(ii). There is nothing in this section regarding the liners in the current PAP version. We will need information on how the native material will be recompacted as proposed, how a permeability of 2X10 -7 will be achieved, and what testing procedures will be used to verify the permeability. Please also describe how bentonite will be used if needed, where it will be obtained, and what will be the total thickness of the liner if bentonite is mixed to achieve the desired permeability. Please update section 2.05.3 with the requested pond liner information. 9. Please describe how the sediment ponds will be cleaned so as to not damage the liner. As stated on revised pages 2.04 -37 and 2.05 -48 and shown on Map 13, a 12 inch thick liner will be used in all three sediment ponds. The Division requests that the permit text be revised to describe the method that will be used to maintain the full 12 inch thick liner after pond cleaning. 10. In item number c at the bottom of revised page 2.05 -50 and at the top of revised page 2.05- 51, the response appears to contain information that does not pertain directly to the Rule in question. Rule 4.18(5)(c) asks for a description of those measures which will be taken to exclude wildlife from entering a pond which contains toxic materials. The Division agrees that special measures such as fences do not need to be employed to protect wildlife from any standing water in the sediment ponds since such water would not be considered toxic. Any possible pond water toxicity might be relevant should the water leave the pond and enter Reed Wash. However, the text on perceived risks and the USFWS conservation measure of a pond lining do not appear to be relevant to Rule 4.18(5)(c). Please revise the text accordingly.