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Carol Pahlke <br />December 23, 1980 <br />Page 21 <br />Revised Pages: Revised pages 780-112aa through <br />780-116aa were previously submitted to MLRD and OSM <br />as part of the November 21, 1980 response of Kerr <br />Coal to the OSM Apparent Completeness Review. <br />6. The sediment pond below the waste oil storage pond should <br />be monitored for grease and oil. Other ponds and streams need <br />not be analyzed for oil and grease. <br />Response: In accordance with the requirements of <br />Exhibit 33, NPDES Permit, Kerr Coal will visually <br />monitor all discharges for oil and grease. The <br />adequacy of visual monitoring was confirmed by tele- <br />phone with Roy Cox and Carol Pahlke of MLRD on <br />December 9, 1980. <br />Revised Pages: Revised page 780-109aaa was pre- <br />viously submitted to MLRD and OSM as part of the <br />December 4, 1980 response of Kerr Coal to the MLRD <br />November 6, 1980 Adequacy Review. <br />r 9, 1980 Memo to Carol Pahlke from Tom Gillis <br />nn mnnc.,; 1 Cpl v~nn <br />1. There is still concern over Kerr Coal's topsoil salvage <br />plan for pits 1 and 2. Specifically, I am concerned about the <br />salvage depths for the X73 Coalmont soil areas in these two <br />pits. From the data submitted by Kerr Coal in Tables 77 and <br />42a in response to the October 9th MLRD adequacy letter, it <br />appears that more A and B horizon material is available for <br />salvage than is indicated in the topsoil salvage plan. To <br />resolve this problem, Kerr Coal must develop a more suitable <br />plan for these two pits that takes into account actual horizon <br />depths and addresses the suitability of this additional <br />material as a plant growth medium. <br />Response: Although there is more A and B horizon <br />material available in Pit #1 than Kerr Coal proposes <br />to salvage, the quality of the material in those <br />horizons is such that salvage of additional material <br />from this area not only is unjustified, but also <br />could be detrimental to the planned revegetation. <br />As more fully discussed in Section 816.22 (c) and (d) <br />of the Permit Application, and as clearly shown in <br />Table 42a, the Coalmont areas (X73) in Pit $1 are of <br />very poor quality. Specifically, the soil texture <br />