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Section N -Decision to R.~g~.tire Revisions <br />As a result of [his midterm review, the Division will require revision(s) of the permit [o address <br />the following concerns with the currently approved Marr Strip Mine permit application. The <br />Division will require that Kerr Coal Company submit a complete revision application to address <br />the items listed on or before November l6, 1998. <br />I had some difficulty finding where certain of the Colorado regulatory requirements were <br />addressed in the Marr Strip Mine permit application, because it is organized according to the <br />Federal Regulations. Please let me know if I commented on a topic that is already addressed. <br />General <br />1. The introduction of the permit application provides a good history of the operations. An <br />update to the end of this section would be helpful to include mining and reclamation <br />activities that have occurred since August, 1990 when it was last revised. <br />Rule 2.05.4 -Reclamation Plan <br />2. It would also be helpful to update the general description of the operation plan, Section <br />780.11(a) and the reclamation plan, Section 780.18(b) in the permit application to reflect <br />the current conditions. A summary of what activities have occured and the current status <br />of the mine site should be added to these sections. <br />Map 47, Actual Reclaimed Topography needs to be referenced in the updated text. The <br />reclamation timetable starting on page 780-58 which is part of the reclamation plan in <br />Section 780.18(b), needs to reflect remaining reclamation activities. <br />3. Pond G was constructed in advance of future mining that did not occur. This pond is not <br />collecting runoff from a disturbed area. BLM has requested (verbal communication with <br />Jim Perry, August 4, 1998) that this pond be removed. On page 780-9 and 10 it says that <br />all ponds will be completely removed and reclaimed after the disturbed azea served by the <br />pond has been restored. Since this pond does not serve a disturbed area, it can be removed <br />now. A schedule needs to be provided. <br />4. On page 780-12, the permit says that upon permanent cessation of operations, all mine <br />facilities will be dismantled and removed from the site and the areas regraded, topsoiled <br />and revegetated. This has partially occurred, however some facilities are still on site. <br />The fuel storage tanks are still on site, although past inspection reports say they will be <br />removed. There has been talk of keeping the warehouse as a petmanent facility. The <br />permit needs to be revised to accurately reflect what the facility reclamation plan and <br />schedule are. <br />Marr Strip Mine, C-BO-006 7 September 16, 1998 <br />Midterm Review Fourth Permit Term <br />