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8-2. Reduction in monitoring. Kerr is proposing to eliminate ground water <br />monitoring wells: 79-1, 79-2, 79-3 and 79-61 at the mine. The DMG concurs <br />with eliminating the water quality sampling for these wells, but not the water <br />levels. Water levels should be monitored semi-annually. This information will be <br />informative, especially coupled with spoils aquifer measurements in the newly <br />installed wells. Water quality monitoring may be necessary at bond release to <br />confirm the anticipated impacts of mining. <br />Groundwater sites AP-3 and AP-4 at the loadout can be dropped. The results <br />have been consistent over the years. <br />Kerr has also requested to changes to surface water monitoring. The DMG <br />concurs with the proposal to eliminate Sites 300, 306, 322 and 327. Sites 314, <br />316, 317 and 3l8 should be retained to provide valuable data when flowing and to <br />collect information at the time of bond release. <br />8-3. Elimination of water quality parameters. The proposed list of pazameters <br />for groundwater (p. 108c) and surface water (p. 109b) aze acceptable. <br />8-4. Table 61 needs to be revised to include the designated monitoring <br />locations and to reflect the approved revisions. <br />9. Kerr submitted TR-18 to address the reclamation of the loadout. Reclamation is <br />scheduled to occur during the 1999 field season as stated in your December 15, <br />1998 letter. Please revise page 780-63a to reflect this commitment. <br />10. Kerr has submitted a revised rill and gully stabilization plan. One additional <br />component should be added to the plan. For excessive gully formation on <br />reclaimed areas Kerr needs to identify and correct the causal agent(s), and then <br />proceed with the necessary repairs as described on revised page 816-142. <br />11. A revised weed control plan has been presented starting on page 780-83. The <br />primazy weeds to control are Canada and Scotch Thistle. Kerr is proposing to use <br />2,4-D and picloram. The timing of application has not been addressed. For best <br />results 2,4-D is applied postemergence in spring or early summer when young <br />vegetation is actively growing. Picloram is applied any time after growth begins <br />in the spring before full bloom, and late in summer or fall up to 3 weeks before <br />frost. The timing needs to be addressed in the application. <br />12. Kerr submitted a vegetation monitoring report that was completed in 1996. This <br />report addresses reclaimed mine azeas that were seeded prior to 1981, in 1981, <br />1984, and 1986. The data is helpful to evaluate vegetation establishment in those <br />azeas. To date no monitoring has been conducted in the Pit 1 Area (seeded in <br />1996) or the 720 Pit (seeded in 1995). <br />