INSPEC46334

• Permit No: C1980006
• IBM Index Class Name: Inspection
• Doc Date: 6/12/2001
• Doc Name: COAL INSPECTION REPORT
• Inspection Date: 5/22/2001
• Media Type: D
• Archive: No

III. COMMnnENTS -COMPLIANCE ~~ S'T/';~ /1'J~t~. C_90-0~
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Below are comments on the inspection. The comments include discussion of observations
made during the inspection. Comments also describe any enforcement actions taken during
the inspection and the facts or evidence supporting the enforcement action.
This was a partial inspection of the Marr Strip Mine conducted by Jim Stark and Sandy
Brown of CDMG. The purpose of this inspection was a partial Phase II Bond Release
for the 720 Pit and Pit 1 and a partial Phase I Bond Release for the Loadout. George
Patterson and Jim Mossman of Kerr, Henry Austin of the OSM, Jerry Nettleton of
Montgomery Watson, John Morrone and Chuck Cesar of BLM and Tootie Crowner of
Jackson County were present. The weather was warm, sunny and windy and the ground
was dry.
Introduction
Kerr Coal Company (Operator) is requesting a total bond release of $1,130,444.00 for the
three areas listed above. Amore complete breakdown for each area is provided below. The
Division currently holds a bond in the amount of $1,817,911.00.
For Phase I Bond Release "Up to sixty percent of the applicable bond amount shall be
released when the permittee successfully completes backfilling, regrading and drainage
control..." (Rule 3.03.1(2)(a)).
For Phase II Bond Release "Up to eighty-five percent of the applicable bond amount shall be
released upon the establishment of vegetation which supports the approved post mining land
use and which meets the approved success standard for cover..." (Rule 3.03.1(2)(b)) and
"For vegetative cover the revegetated area shall be considered acceptable if it is not less
than 90 percent of the cover determined from the reference area or approved standard with
90 percent statistical confidence..." (Rule 4.15.8(3)(a)). Further, "No more than sixty (60)
percent of the bond shall be released so long as the lands to which the release would be
applicable are contributing suspended solids to streamflow or runoff outside the permit area
in excess of premining levels..." (Rule 3.03.1(3)(b)). The approved post mining land use for
the Marr Strip Mine is rangeland.
Phase II Bond Release for the 720 Pit
The Operator is requesting a 25% ($904,674.00) Phase II Bond Release for the 720 pit. The
total cost for reclamation of the 720 pit was $3,618,694.00. The reclamation for this area
was completed in 1995. The criteria that were observed were vegetative cover, topsoil
replacement and hydrologic reclamation (sedimentation).
Vegetative Cover -According to the Bond Release Application submitted by the Operator,
the vegetative cover in the reference area was 30% and the cover for the reclaimed area was
37.3% or 124% of the premining cover. This exceeds the standard set forth in Rule
4.15.8(3)(a). The inspection confirmed that the cover on the reclaimed area was acceptable.
There were no large bare spots and the overall vegetative cover appeared to be uniform.
There was no observable erosion in the 720 Pit area confirming that the vegetative cover is
adequate to control erosion.