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- 7 - <br />locate all areas on a map where the diversion ditches will be located and <br />provide a discussion of the specific suitability as a plant growth medium <br />of each soil type that will not be salvaged. Also indicate what volume <br />of topsoil will not be salvaged from each ditch, <br />32. Please define what "certain circumstances" (page 2.05.3-39) will <br />determine when topsoil removal may occur during winter and spring. KCC <br />should ensure that these circumstances will comply with Rule 4.06.2(5). <br />33. A statement on page 2.05.4 - 18 of the PRP claims that "Kerr will not <br />attempt surface preparation of the regraded spoils prior to (stockpiled) <br />topsoil replacement unless there is excessive compaction". Rule <br />4.06.4(11 states "Where necessary to eliminate slippage surfaces, relieve <br />compaction and to provide for root penetration, regraded land shall be <br />loosened by mechanical means to a sufficient depth or otherwise treated <br />as approved by the Division." The Division believes that the nature of <br />the overburden material at the Marr Mine is such that ripping all areas <br />of replaced overburden may be appropriate. <br />34. The staff has reviewed the information provided by Kerr Coal Company in <br />sections 2.05.4, 4.15.4 and in Exhibit 33 regarding soil stabilization. <br />The Division does not believe that there is adequate evidence that a <br />roughened surface, timely seeding or placement of topsoil, establishment <br />of living snowfences and contour furrows will be adequate measures to <br />protect the soil resource in an expedient manner. A coal operator is <br />required to utilize specific soil stabilization practices on all regraded <br />and topsoiled areas to prevent, to the extent possible, contributions of <br />suspended solids to the streamflow (4.15.4 and 4,05.5(2)(f)), The <br />practices outlined by Kerr within this application do not maximize <br />erosion control protection. While the aforementioned practices do <br />contribute to erosion protection, the Division requests that they be <br />coupled with some method for incorporating organic matter into the soil. <br />Please eliminate Exhibit 33 and the BLM test results in section 4.15.4 as <br />the citations reflect inappropriate uses of data. Then, revise the <br />permit revision to meet the requirements of 2.05,4(2)(e)(iv), <br />4.05.5(2)(f), 4.09.1 and 4.15.4. <br />35. Page 2.05.4-39 makes vague commitments to implement supplemental soil <br />stabilization techniques where soils are exposed to greater than average <br />wind or water erosion. What criteria will be used to determine where <br />greater than average wind or water erasion will occur? Please identify <br />the areas on the mine site where these techniques will be used. <br />36. Also on page 2.05.4-39, a commitment to use contour furrows where <br />required is stated. What specific criteria for scopes will be used to <br />determine when contour furrows will be installed? Also, what criteria <br />will be used to determine spacing and size of these furrows? <br />37. Kerr has requested a variance from soil testing and fertilization on Doge <br />2.05.4-50, The Division agrees that fertilization may be limiting to <br />shrub establishment from seed under very specific circumstances. <br />