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Mr. David Gossett - 2 - November 16, 1989 * If there are sodic zones in the overburden, Kerr must consider the ramifications in the back filling and grading plan by addressing the rules associated with disposal of toxic materials. Narrative in the permit application should include discussion on badcfilling these materials out of the predicted groundwater zones and below the rooting zone. An assessment on leaching into the surface water system through runoff and erosion should also be prepared. * Kerr has not made an acceptable demonstration that 6" of topsoil will enhance reclamation objectives at the site and the Division requests that all soil resources be salvaged. * The Division will consider the practice of using live topsoil as a sole-seed source on a limited test basis if conditions of the test are thoroughly documented in advance. The Division will not permit the practice on a mine-wide basis until site-specific evidence of the success of this practice is documented. * The primary objective of regulations related to soil stabilization center around erosion prevention and minimization of contributions of suspended solids to stream flow. While Kerr's proposed soil stabilization practices are a component of an erosion prevention program, they do not provide the protection afforded by incorporation of organic matter into the soil. Please propose a reclamation practice which will accomplish this goal. * The hydraulic designs associated with the post-mining drainage plan designs need to be tied to the 100-year 24-hour precipitation event. * The Division requests that Kerr maintain the approved standard for vegetative cover success of total plant cover. Other issues are addressed in this adequacy review letter. Many request clarification. If it is clear that we have not found pre-existing discussion in the permit application, please reference specific pages in your response and we will examine them. The Division would like to emphasize that this letter is a preliminary set of questions based on an overview of the permit revision. As many broad based components of the reclamation plan will undoubtedly be modified in addressing our concerns, there may be additional sets of adequacy questions. There are several references to the Division's Guidelines for Compliance with Land Use and Ve etation Requirements of the Colora o ine an ec ama ion Boar or oa Mining. is p icat~on was sent to coa operators aroun the s a e in ove~Tm er,T488, and is available in our office. Let me know if you need another copy.