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recompacted as proposed, how a permeability of 2X10 -7 will be achieved, and <br />what testing procedures will be used to verify the permeability. Please also <br />describe how bentonite will be used if needed, where it will be obtained, and <br />what will be the total thickness of the liner if bentonite is mixed to achieve the <br />desired permeability. Please update section 2.05.3 with the requested pond <br />liner information. <br />CAM: Please see requested pond liner information beginning on page 2.05 -19. <br />Section 2.05 -3 will be included in entirety due to revised page numbering. As <br />referenced in revised Section 2.05 -3, there will be a new Exhibit 20 which <br />incorporates Quality Assurance Measures for Sediment Ponds 1 -3. <br />9. DRMS: Please describe how the sediment ponds will be cleaned so as to <br />not damage the liner. As stated on revised pages 2.04 -37 and 2.05 -48 and <br />shown on Map 13, a 12 inch thick liner will be used in all three sediment <br />ponds. The Division requests that the permit text be revised to describe the <br />method that will be used to maintain the full 12 inch thick liner after pond <br />cleaning. <br />CAM: Please see the sediment cleanout discussion on page 2.05 -20. <br />10. DRMS: In item number c at the bottom of revised page 2.05 -50 and at the <br />top of revised page 2.05 -51, the response appears to contain information that <br />does not pertain directly to the Rule in question. Rule 4.18(5)(c) asks for a <br />description of those measures which will be taken to exclude wildlife from <br />entering a pond which contains toxic materials. The Division agrees that special <br />measures such as fences do not need to be employed to protect wildlife from any <br />standing water in the sediment ponds since such water would not be considered <br />toxic. Any possible pond water toxicity might be relevant should the water leave <br />the pond and enter Reed Wash. However, the text on perceived risks and the <br />USFWS conservation measure of a pond lining do not appear to be relevant to <br />Rule 4.18(5)(c). Please revise the text accordingly. <br />CAM: Please see revised pages 2.05 -51. Reference to the USFWS <br />conservation measures has been removed. <br />11. DRMS: The first sentence in Section 2.05.6(3)(b )(ii) on revised page 2.05- <br />56 states that alternative sediment control will be used to treat surface runoff <br />from the facilities area. However, the Division's Rules considers sediment ponds <br />to be a primary sediment control measure. Please revise the sentence <br />accordingly. <br />CAM: Revised text on page 2.05 -56 to include treatment with sediment ponds. <br />12. DRMS: The last sentence in the first paragraph of Section 2.05.6(3)(b)(iv) on <br />revised page 2.05 -61 states that the coal operation does not have the potential to <br />