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- 4 - <br />rologic Balance - Rules 2.04.5, 2.04.7, 2.05.3(4), 2.05.6(3 <br />18. The potential for degradation of runoff water is increased because <br />of shallow topsoil replacement cover and high S.A.R. levels in the <br />overburden. The operator should address this possibility through <br />mitigative measures to prevent leaching to toxic materials (Rules <br />4.05.8(1) and 4.05.8(2)) and through projections of sodic loading <br />on surface water per Rule 2.05.6(31. <br />19. Please update the hydrology section (2.04.7) of the application to show <br />the results of ten years of subsequent monitoring at the site. Tables <br />16 through 23 reflect hydrology data collected prior to initial <br />permitting in 1979 and 1980. Please provide analyses in graphics when <br />possible. Hydrographs should be developed to show seasonal fluctuations <br />of flow and water levels. When water quality of undisturbed areas does <br />not change on a seasonal basis, it may be scientifically valid to perform <br />statistical summaries of the data. Data from sites which have been <br />disturbed or from sites where water quality varies on a seasonal basis <br />could be tabulated by millequivalents seasonally and annually as shown in <br />the example provided in Appendix 2. <br />20. The Division is unable to find a demonstration according to Rule 4.05.18 <br />that indicates that stream buffer zones are not required on any of the <br />intermittent drainages that are within the permit area. Please provide <br />such a demonstration if stream buffer zones will not be established per <br />Rute 4.02.5. <br />21. Section 4.05.4 states that Sudduth, Bush, Williams, and Bolton Draws will <br />be protected by stream buffer zones. Section 4.02.5 indicates that they <br />will not be protected by stream buffer zones. Please clarify and provide <br />narrative in the revised permit revision which complies with Rules 4.02.5 <br />and 4.05.18. <br />Soil Resource Information - Section 2.04.9, 2.05.3(5), 2.05.4(2)(d) and 4.06 <br />22. The Division is unable to accept KCC's contention that drill holes <br />showing lithologies with high SARs were contaminated with drilling fluid <br />(page 2.04.9-21-. The Division has noted sodic problems in the North <br />Park area previously and ESP data confirms the existence of zones with <br />excessive sodium. Please revise the overburden chemical analyses to <br />include data from Holes 028-77-12, 028-77-14C or re-drill near these <br />original sites to acquire data in four foot intervals which substantiates <br />your assessment that the wells were contaminated. Kerr contends that <br />these two holes lie outside the proposed pit disturbance area, but this <br />is not backed up by Map 11. <br />23. Compositing all overburden and topsoil data into one number to determine <br />overall suitability of overburden and topsoil (as done in Table 34) is <br />unacceptable. Overburden strata are proven by borehole data to be highly <br />variable with respect to sodium, calcium, magnesium and other parameters. <br />Baseline topsoil investigations indicate the same type of wide <br />variability with respect to texture, pH, SAR, and other factors. <br />