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,'.. <br />THE AERIAL VOLUMETRIC SURVEYING PROGRAM DESCRIBED ON PAGE 816-124 OF THE 'APPLICATION, <br />TO DETERMINE WXETNER FUTURE OPERATIONAL EXPERIENCE IS CONSISTENT WITX TXE PROJECTED <br />SWELL FACTOR OF 24$. ' <br />XVII Coal Processing Waste and Non-Coal Processing Waste (2.05.3(8), 2.05.4(2)(f), <br />4.I0, 4.11) <br />No problems relative to these requirements were identified. The proposed <br />operation is in compliance. <br />.YVIII ?4ine Facilities, Coal N.andling Structures, Support Facilities (2.05.3(3), <br />2.05.3(7), 4.04) <br />No problems relative to these requirements were identified. The proposed <br />operation is in compliance. <br />XIX Roads (2.05.3(3), 4.03) <br />Kerr Coal initially provided insufficient road designs which were needed to verify <br />that all existing and proposed roads were in compliance. Kerr Coal adequately <br />responded by supplying all needed designs. The following issues were raised <br />and have been satisfactorily resolved. <br />1. Road surfacing materials were deemed suitable. <br />2. Road grades and drainage are now in compliance. <br />3. As was requested, Kerr Coal is hereby granted a variance from the <br />culvert spacing requirements of Section 4.03.1(4)(e)(vi). The variance <br />was granted because: <br />a. A11 haul roads are within a sediment control system. <br />b. Culverts were properly sized and located at all major intermittant <br />and ephemeral drainages. <br />c. Road ditches were adequately designed. <br />d. Ditch relief points are properly located, sized, and will be <br />maintained. <br />e. Road grades were not excessive. <br />4. The existing road at the Marr pit is hereby approved as is. Drainage, <br />road grades, pitch, and surfacing are in compliance. Past inspections <br />of the road indicate that it has been properly maintained. <br />5. Revised culvert calculations submitted by Kerr Coal indicate. that all <br />relocated County road culverts are properly sized to make them compatible <br />with Kerr Coal operations. <br />The existing and proposed operation is in compliance. <br />XX Bonding (2.05.4(2](bJ) <br />Kerr Coal has proposed an incremental approach to bonding the Marr Strip, based on <br />bonding units indicated on Map 46. Worst case reclamation cost estimates have been pro- <br />vided for the first bonding increment (pages 780-63aaaaaaaa through 780-63iiiiiiii, <br />Exhibit 58a). As initially submitted, several problems were identified in the <br />reclamation cost estimates, of which the following were the most significant; <br />1. Operating costs were not consistently included in the calculated hourly <br />mobile equipment costs, <br />2. For the conveyor system, the initial bonding proposal included only the <br />interest on the capital necessary to purchase the conveyor. The Division <br />requested that Kerr obtain leasing cost estimates for the system. <br />-25- <br />