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IA. Revisions Required. 1. Legal. Flnanclal, Compliance Information - The Division finds that the following information 1s inaccurate and needs to be updated to reflect changes that have occurred over the past 2 1/2 years. Specifically: a. It 1s the Division's understanding that Kerr Coal Company has undergone changes in corporate structure since the Issuance of the permit in 1981. Kerr Coal Company should revise all sections pursuant to Rule 2.03 1n which a change has occurred. b. Since the Kerr Coal permit application was submitted prior to initiation of the permanent program in Colorado, the permit application is keyed to the applicable federal rules an/or statutes. For clarity, Kerr Coal should modify or provide a cross-referencing Index between State and Federal Regulation citations within the document. 2. Land Use a. Within section 779.22 (Land Use information), and within section II (Land Use) of the CMLRD proposed decision, the operator and the Dtvislon found that the designation, "rangeland" best described the post mining land use at the Marr Strip. At this time the Division feels that an additional designation of "wildlife habitat" should be incorporated into the designated post mining land use, given the amount of concern regarding wildlife which was expressed during the permit review. The Division is not proposing that Kerr Coal Company change post mining land use designations, rather that the designation "wildlife habitat" be added to the existing land use of rangeland to form the post mining land use, "rangeland/wildlife habitat". With respect to the additional requirements of Rule 4.18.4(1) for those areas with primary or secondary land uses of wildlife habitat, the Division finds that these requirements have already been fulfilled by Kerr Coal in their approved revegetation plan. 3. Hydrologic Balance: Ground and Surface Water a. The Division has reviewed surface and ground water monitoring information collected between 1979 and 1983, contained in the permit application and annual hydrologic reports. The only ma3or concern identified in the review of this data concerned well 79-3, completed in the overburden. Samples from well 79-3 show higher concentrations of calcium, potassium, and chloride, and lower concentrations of sulfate than upgradlent wells. These concentrations are not consistent with background natural conditions, or with concentrations modified as a result of mining activity. The Dtvislon feels that this well has been contaminated in some way, probably through incomplete flushing of the well during completion. Kerr Coal Company should pump the well until electrical conductivity levels stabilize, which should eliminate any contamination, and then continue monitoring according to the approved plan.