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

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Corey Heaps CAM Colorado LLC January 13, 2012 Page 3 11. The first sentence in Section 2.05.6(3)(b)(ii) on revised page 2.05 -56 states that alternative sediment control will be used to treat surface runoff from the facilities area. However, the Division's Rules considers sediment ponds to be a primary sediment control measure. Please revise the sentence accordingly. 12. The last sentence in the first paragraph of Section 2.05.6(3)(b)(iv) on revised page 2.05 -61 states that the coal operation does not have the potential to negatively impact the ground water quality. However, it has already been determined that the potential does exist. Therefore, please omit this sentence from the permit application text. 13. Revised Map 13 is titled "Drainage Plan — Ponds 14". Please revise the map title to read "Drainage Plan — Ponds 1 -3 ". 14. In Section 2.05.6(3)(b)(iii) text regarding the coal leachate analysis should be revised due to several inconsistencies noted in the discussion of laboratory results beginning on page 2.05- 58. The data table at the top of page 2.05 -58 should be footnoted for RW -1 to differentiate between total or dissolved species for Iron and Manganese. In the last paragraph of page 2.05 -58 the statement that average dissolved and total manganese concentrations are 0.95mg/1 is incorrect according to the laboratory data presented in Exhibit 3 of the PAP. The second to last sentence of the same paragraph states: "The total iron concentration is below reporting limits." It would be more accurate to state: The total iron concentration is below the method detection limit used by the laboratory. On page 2.05 -59, the last sentence of the second paragraph should be revised as follows: "Therefore, leachate from the coal pile will not increase conductivity and TDS concentrations in the groundwater in the vicinity of the coal pile." The first and last sentences of the third paragraph should be revised as follows: The selenium concentration in the coal leachate is below the method detection limit used by the analytical laboratory; and the third sentence revised as follows: "The coal pile leachate should not add to the dissolved selenium concentration in groundwater." In the fourth paragraph please verify the RW -1 manganese concentration and state dissolved. The last sentence of this paragraph should read: The coal pile leachate should not increase the manganese concentration in the groundwater. In the fifth paragraph replace the second sentence with: "RW -1 has a dissolved iron concentration of 0.0743 mg/1." Please revise the PAP text accordingly, if deemed appropriate. 15. Please incorporate the January 12, 2012 correction letter from the Office of Surface Mining into the PAP and ensure that all correspondence and documentation pertaining to the BA and BO have been incorporated into Exhibit 19. 16. In Section 3.02 of the original submittal CAM prepared a cost estimate. This estimate is low compared to the liability calculated by the Division. The Fruita Loadout bond liability is estimated to be $1,128,070.00 (sent previously under separate cover). This does not include water disposal costs which are necessary, since the ponds cannot discharge and we assume they would be full in the unlikely event that bond is forfeited. Attached is the RAW cost for