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