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• Kerr will not be reclaiming Ponds A, B, D and E. as originally proposed. <br />Therefore, the topsoil that is stockpiled for their reclamation will not be needed. <br />According to Table 71 Mine Area Soils Plan, of the permit application, the <br />facilities will be covered with 7,800 cy of topsoil and the Ponds A, B & D with <br />7,350 cy. Pond E is not listed in the Table and topsoil should have been stockpiled <br />for the access road. Given that these facilities will be retained what are the <br />revised topsoil balances'? Has Kerr considered using that topsoil at the loadout <br />where there is a minimal amount of available topsoil? <br />The DMG approves the retention of the mine office/shop/warehouse building, <br />sedimentation ponds A, B. D and E, two water supply wells (Permit No. 020253- <br />F at the mine and Permit No. 23696-F at tipple), the light-use access road at the <br />loadout and the cinderblock loadout shop building. <br />5. Kerr Coal Company submitted a rider to the bond. DMG received one this fall, <br />however the rider was for an increase rather than a decrease. Debbie Mulloy of <br />our ofFice contacted Freda at Van American Insurance on December 21, 1998 and <br />asked her to reissue the rider using the correct form. To date we have not <br />received the reissued rider. <br />6. Although, Kerr requested and received approval to retain the light-use entrance <br />road in MR-25, the BLM was not consulted. Part of the road is on BLM managed <br />land, SENE and NWSE of Section 26, and BLM did have a comment on the <br />portion of the road under theirjurisdiction. These sections are currently under a <br />BLM lease. Prior to coal lease expiration, Kerr Coa! will need to apply for and <br />receive a BLM right-of-way for use of the road. If the right-of-way is not <br />granted, those sections of the road will need to be reclaimed. <br />7. Figure 39, Erosion Protection As-Built for Ponds A, D and E was not included <br />with the package of information. Please provide this figure. <br />8. Kerr has requested several changes to the hydrologic monitoring plan. These are <br />discussed below. <br />8-1. Spoils Wells. Kerr has requested that the number of spoils wells be reduced <br />from three to one in the northern (letter says central) portion of the 720 pit. The <br />DMG believes that two wells would be appropriate, the one proposed in the 720 <br />pit and also one in Pit 1. The DMG believes they are two different systems, that <br />may behave independently. Data collected from these two wells will enable the <br />DMG to make a finding with respect to the recharge capacity of the coal seam and <br />reestablishment of the aquifer as predicted in Ken's statement of probable <br />hydrologic consequences. These wells should be installed in 1999, not waiting <br />until 2000. DMG believes there has been adequate settlement and consolation. <br />Map 48 was not submitted as referenced for the proposed location of the spoils <br />well or the proposed ground and surface water monitoring sites. <br />