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,1/arrh 1995 Km Coal Company • Rtrponra ro TR•f1 Adtq,ucy Concrrns ~ ~ <br />usuming a phreatic surface at 30 feet below the ground surface, still results in an <br />adequate FS of 1.5. <br />10) The permit calls for sampling for overburden tonicity in dx mlaim areas, Samples bast <br />been taktn by rlx operator but harx not come back from the lab. The Division wisJxt ro see <br />the sampling molts when atailable and mould like an rrwluation of six molts in relation <br />to commitmnttr to se/ectirxly faxnd/e and cover areas that show potential toxicity. llxse <br />results should 6e revieuxd prior to topsoil redistribution. <br />Response Receipt, review, and evaluation of overburden sampling results resulted in an <br />indiction of possible sodium toxicity for two separate ueu. In consultation with the <br />DMG the suspect ueu were resampled and plans developed to cep one of the ueu with <br />4 feet of suitable spoil material. Kerr completed the apping operation in late June 1994 <br />and subsequently proceeded with topsoil replacement in July 1994. <br />11J SY/irb the reclamation of six 720 Pit and Pit No. 1 areas, an alternatite mlamanon plan <br />must !x devised for;: a• disposal of mattrial from the mlamarion of the laadouS Pit No. 2 <br />haul ramp, and the existing office and shop facilities llx mlamation plan in the permit <br />should br updated to include fill disposal locations and volumes for this disposal Pfaase <br />bond cannot Ee released for shots arras held open for tjx disposal of this material <br />Response The previously submitted response to this comment indicted thu smp <br />equipment and steel resulting from demolition of the office and shop facilities would be <br />hauled off-site for either salvage or disposal in the loaf munidpal landfill. Concrete <br />demolition debris will be buried in a small pit aavated within the fadlities ua and <br />apped with a minimum of 4 feet of suitable cover material. Material from the Pit 2 foul <br />ramp mill be used u supplemental backfill material under the agreement for final <br />reclamation of the former Pit 1 uea. <br />In order co reclaim the loadout uea, Kerr also plans to have any equipment and steel <br />debris hauled off-site for salvage or disposal and to dispose of conarte demolition debris <br />in an e:avated pit on sits The DMG hu ezpressed a concern about on-site disposal in <br />an AVF ua. This is not entirely aavnte beaux the AVF uea has been identified in <br />the permit u an uea adjacent to but not spedfially including the loadout uea. There <br />ue also no spedfic prohibitions in the regulations reguding deposal of nontoal wastes <br />in ueu identified u or adjacent to AVF's. The only appliable prohibition would be <br />prevention of muerial damage of the gttantiry or quality of water assoaued with the <br />AVF. Disposal of congae demolition debris would not result in any material damage <br />to the hydrologic system and this prohibition would therefore not be spedfially <br />appliable to Kerr's proposed final reclamuion plan. <br />The DMG hu also ezpressed a concern relative to disposal of any remaining coal or wal <br />refux u the loadout sits There is no coal refuse at this site given the Rerr never <br />conduced any coal cleaning or other opal preparuion activities other that gushing and <br />sgeening. These ue small quantities of coal and coal fines u the site which will be sold, <br />given-away, or hauled off-site to either the munidpal landfill or the disposal site in the <br />mine fadlities uea. <br />TnraManiz !rtc • P.O. Box 771018 • Swvnbou Springs, Colorado 80!77 (3031 d79b260 <br />