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Page four <br />• Letter to Ms. Carol Pahlke <br />and Mr. Tom Pike <br />Re: Kerr North Expansion <br />April 24, 1980 <br />distance of 1,488 feet between transects utilizing those <br />parameters listed in the attached list entitled "Overburden <br />Analysis List". Certain of the overburden samples taken <br />from these drill holes will also be subjected to leaching <br />studies and sampled for the parameters delineated on the <br />attached sheet entitled "Leachate Analysis List". In addi- <br />tion, a single sample of the coal to be mined at the Kerr <br />Mine will be tested for those parameters identified in the <br />attached "Coal Analysis List". <br />E. •Alluvial Valley Floor Analysis: For purposes of <br />this permit application, KCC concedes that the stretch of <br />the Canadian River floodplain proximate to the permit area <br />is an alluvial valley floor. KCC will accordingly conduct <br />a thorough evaluation of impact or effect upon the Canadian <br />River floodplain, consistent with the requirements of the <br />OSM Permanent Program Regulations, with respect to those <br />particular draws which extend from the permit area to the <br />Canadian River floodplain, specifically Sudduth Draw, <br />Williams Draw and Bush Draw. <br />• F. Water Quantity Analysis: KCC does not have exten- <br />sive long term information on water rates and volumes for <br />the permit area. Short term information on runoff and pre- <br />cipitation, together with long term information on precipi- <br />tation is available and KCC will conduct appropriate cor- <br />relations between runoff and precipitation to extrapolate <br />upon existing runoff data. <br />G. Baseline Water Quality Data: KCC again does not <br />have extensive long term water quality data; however, KCC <br />will use short term data which it has gathered, together <br />with appropriate extrapolating methods to obtain the re- <br />quisite baseline data. <br />III. APPLICABLE COMPLIANCE MEASURES FOR KERR TIPPLE SITE <br />A. Alluvial Valley Floor Considerations: Some concern <br />was expressed as to the existence of an alluvial valley <br />floor adjacent to the Kerr tipple area. In this regard the <br />alluvial valley floor question is answered by the grand- <br />fathering provisions of the Surface Mining Control and <br />Reclamation Act, due to the fact that KCC operated its <br />tipple and shipped commercial quantitites from that tipple <br />during the year preceding August 3, 1977. <br /> <br />