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Carol Pahlke <br />December 23, 1980 <br />Page 4 <br />Prior to removal of sediment or sedimentation pond <br />embankment material, Kerr Coal will identify appro- <br />priate disposal areas. At this time, Kerr Coal <br />anticipates that sedimentation pond sediment and <br />embankment materials may be disposed of at licensed <br />sanitary landfills, or used in nearby road construc- <br />tion areas. Rowever, the specific disposal areas <br />cannot be identified at this time. <br />Section 780.18(B)(5) - Reclamation Plan - General Requirements <br />Kerr's criteria for determination of success or failure of <br />stubble mulch (conveyed in the response to Sec. 780.18(b)(5) <br />of the OSM ACR; revised page 780-67aa) are unacceptable to <br />MLR. The "erosional features" described are not valid for <br />aeolian erosion, and cannot be applied as criteria. Kerr is <br />referred to MLR's comments in the November 6, 1980 letter on <br />this point. Kerr must satisfactorily address erosion poten- <br />tial between the time of seeding of the stubble mulch and the <br />time at which the stubble mulch effectively controls aeolian <br />and water erosion. <br />Response: Kerr Coal responded to this concern at <br />page 21 of its December 4, 1980 response to the <br />November 6, 1980 Adequacy Review of MLRD. <br />Revised Pages: Revised pages 780-73aaa, bbb, ccc <br />and ddd wece previously submitted to MLRD and OSM as <br />part of the December 4, 1980 response of Kerr Coal <br />to the MLRD November 6, 1980 Adequacy Review. <br />With regard to Kerr's response to OSM's ACR section 780.18, <br />MLR has no problem with the inclusion of desert wheatgrass and <br />Russian wildrye sown at the rates given in the Kerr seed mix. <br />Kerr is requested to monitor these species with respect to <br />their role in the vegetation community following reseeding and <br />to report results to the regulatory authority (as part of the <br />general revegetation monitoring requirement of 4.15.1(4)). <br />Should these species present problems, measures will be <br />devised by the company and regulatory authority to remedy the <br />situation. It is noted that desert wheatgrass was not <br />approved for Bourg Coal's final seed mix by the Division and <br />was omitted. Further; Bourg Coal's seed mix was reviewed <br />under interim regulations, nullifying any valid comparison <br />between Kerr's case and that of Bourg. <br />