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a. Pit 2 has dimensions of approximately 450'x1600'. When the text <br />says sample locations will be 200' to 500' apart, what is the <br />minimum number of drillholes which Kerr would plan on drilling? <br />b. The Division's "Baseline and Water quality and Overburden <br />Geochemistry" guidelines, dated September 16, 1982, recommend a <br />sampling interval of 4' for thinly bedded strata. There is no <br />specific recommendation on compositing thicker bedded units. <br />However, the Division has usually requested that the entire column <br />be sampled on four foot intervals. A review of guidelines from <br />other western states shows that they are requesting sampling at <br />5' intervals for chip samples and 10' intervals for core samples. <br />Please revise the discussion on 780-70aaaa to reflect a tighter <br />sampling interval than twenty feet for thick, relatively uniform <br />strata. <br />c. Given the historical difficulties with overburden geochemistry data <br />from Kerr, and the relationship of ESP values to long term <br />geochemical environments, the Division respectfully requests that <br />SAR and ESP be analyzed separately rather than deriving ESP from a <br />nomograph on SAR. In addition, the Division requests that selenium <br />be included in the parameter list as drillholes 028-79-61, <br />028-80-28c, and 028-80-29c showed levels of selenium which exceed <br />Montana's recommended standard of 0.1 mg/k g. <br />d. Collection of baseline information as required under Rule 2.04 <br />allows plans to be prepared in accordance with Rule 2.05 which can <br />meet the applicable performance standards of Rule 4. This <br />necessarily entails collection of baseline data prior to, not <br />during, mining and/or mine development activities. KCC must commit <br />to a more extensive sampling program in the Pit 2 area prior to any <br />more development in that area so that the Permit Application <br />Package complies with Rule 2.04.6. <br />e. Please review the MLRD Permit Revision Adequacy letter, questions <br />24-39. If permit modifications were made in the Mid-Term which are <br />related to any of those questions, please address the question and <br />change the narrative accordingly. <br />4. a. There still appears to be a discrepancy between the elevations <br />identified on Map 15a, and that recorded in revised Table 62a for <br />Well 028-79-61. <br />b. In retyping Table 62a, a typographical error was noted for <br />028-DH-36. The staff believes the total depth should be 160'. <br />c. The casing information found on the bottom of Table 62a reflects <br />inappropriate completion techniques for the bedrock, non-alluvial <br />wells. Coal wells that have slotted casing throughout their <br />100'-500' lengths result in comingling of aquifers and the failure <br />to identify the zone of monitoring interest. Please propose a plan <br />to obtain water quality data reflective of the zone of interest. <br />-3- <br />