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~. . Memo - Cathy Begej - C-80-006 - 2 - June 15, 1990 2. If mining proceeds to Pit 2, overburden geochemistry sampling needs to be done prior to the start of mining; not as mining proceeds. KCC has presently cononitted to no overburden sampling in the Pit 1 area and overburden sampling in Pit 2 which would only identify possible problems. A selective handling plan would only be developed if secondary sampling (surface to a depth of four feet on regraded overburden) indicated that mixing of overburden was not sufficient to solve the problem (see pages 780-70aaa and 780-70aaaa for details). This scheme may answer problems to plant growth caused by sodic and/or acid overburden in Pit 2. However, once backfilling proceeds to this point, it will be too late to do anything about deeply buried overburden which may affect ground water. 3. KCC's numbers on the amount of topsoil available in stockpiles and thie minor amount still to be stripped indicate that they have just enough to spread 6 inches on all remaining disturbance in the area. I have not: yet been able to check to see if Tabtes 57 and 58 or maps 31a and 32 have been updated to indicate the changes in the topsoil handling plan. 4. KCC may need to update page 780-19aa to indicate changes in the Overburden Stockpile section. 5. Pre-mining contours are needed on Map 38 for Approximate Original Contour comparisons. None.of the tables submitted on April 20, 1990 have a revision date on them. 7. Table 74a-Pit Volume Calculations indicate that Pit 1 volume is 4,214,100 CY yet it will only be backfilled with 1,795,000 CY. Are they really this short of overburden? If so, it may pay to get a commitment that if mining proceeds in Pit 2, overburden from Pit 2 will initia lly be backfilled into Pit 1 and mining proceed from there. 8. Timetables for backfilling and reclamation of the 720 Pit do not coincide. See page 780-3ccccccc versus page 780-62bb. You may want to check the Settlement Agreement to see if a timetable and/or minimum amount of backfilling was ordered by the MLR Board prior to signing off on the 300,000 CY backfilled per year as proposed in TR-07, 9. I cannot help but point out that, in the last paragraph of page 780-68aa, KCC dedicates equipment that has reached the end of its economic use life to exclusively backfilling the 720 Pit. I have more concerns relating mainly to overburden geochemistry and sampling that will be covered at a later date. It is also a fairly uncomfortable position for me to be in to review just a part of the entire April 20, 1990 KCC submittal since this small part is related to other parts of the submittal and the presently approved Permit Application. I believe that if we approved just the pages you have highlighted it may tend to make a permit document that would be somewhat contradictory. I would encourage KCC to clearly state which parts of the submittal they want considered now and which parts later. /e rn cc: Susan McCannon 7906F