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<br />Coal were insufficient to determine if a potential problem <br />might exist. <br />D. The periodic removal of sediment from the pond can result in <br />physical mixing of sediment and topsoil. Although it is <br />possible that a careful monitoring of pond cleaning operations <br />could substantially reduce this potential, the chances for error <br />would be high. Analyses of sediment submitted by Kerr Coal to <br />date indicate that this material would not be a desireable <br />addition to the topsoil, because of its high clay content, if <br />for no other reason. <br />Kerr Coal has proposed to monitor the chemistry of topsoil and sediment <br />within the ponds, in an attempt to demonstrate that the topsoil is not <br />being adversely affected. To obtain more information on this subject, <br />this Division is willing to authorize such a monitoring program for <br />the existing ponds A through E. (topsoil has not been salvaged from <br />at Least two of these ponds) If Kerr Coal can in fact demonstrate, <br />on the basis of this monitoring program, that adverse effects on the <br />toasoiZ are not occuring, this Division would be willing at that <br />time to consider a variance from topsoil salvage requirements for <br />future pond construction. However, the sampling program must be <br />framed out over a sufficient period of time to determine if there is <br />any trend towards salinization and/or alkalinization of the topsoil. <br />In order to determine whether or not heavy metals are being concentrated <br />in the topsoil, the following parameters should be added to the list of <br />analyses proposed by Kerr Coal: <br />1. Arsenic 5. Mercury <br />2. Boron ~ 6. Molybdenum <br />3. Copper 7. Selenium <br />4. Lead 8. Zinc <br />Finally, in order that the topsoil - sediment interface may be acurately <br />identified in the sampling program, this Division would suggest that <br />a benchmark be installed at the sampling sites. <br />In light of the above considerations and in order for this Division to <br />make a finding that the proposed operation is in compliance with the <br />topsoil salvage requirements of Rule 4.06, the following stipulation <br />is necessary: <br />KERR COAL IS REQUIRED TO STRIP TOPSOIL FROM TXE IMPOUNDMENT AREA OF <br />ALL SEDIMENT PONDS REMAINING TO BE CONSTRUCTED UNLESS TXE DIVISION <br />SPECIFICALLY AUTHORIZES LEAVING THIS TOPSOIL IN PLACE, BASED ON A <br />DEFIONSTRATI0N BY KERR COAL THAT SEDIMENT COLLECTED IN EXISTING PONDS <br />FALLS NITHZN THE PARAMETERS OF NORMAL SOIL MATERIAL, AND FURTHER THAT <br />THE TOPSOIL BENEATH SUCH ACCUMULATED SEDIMENT DOES NOT DEMONSTRATE <br />ADVERSE IAfPACTS FROM SEDIMENT DEPOSITION OR WATER RETENTI~ OR SHOW ,~ <br />TREND TOCdARD UNACCEPTABLE SOIL PARAMETERS. SUCH DEMONSTRATI017 SHALL <br />BE BASED UPON TXE RESULTS OF TXE SEDIMENT AND TOPSOIL SAh1FLI:VG PROGRAM <br />PROPOSED BY KERR COAL, WITH TXE ADDITION OF THE FOLLOWING PARAMETERS <br />TO THE ANALYSES: ARSENIC, BORON, COPPER, LEAD, IIERCURY, MOLYBDENUM, <br />SELENIUbf, ZINC. IF KERR COAL SHCULD CHOOSE NOT TO IMPLEMENT THIS <br />SAMPLING PROGRAM, TOPSOIL MUST ALSO BE STRIPPED FP.OM THE EXISTING PONDS. <br />-21- <br />