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-4- 4. One additional concern was noted. The texture of the various samples in the 1980 data was listed as either sandy loam or clay, and all of the 1983 samples were characterized as clay. Page 1 of Appendix H states that the textural classification was produced without a particle size analysis and further states: the soil textural data may not represent sufficiently precise determinations to merit serious evaluation as to their suitabilities for reclamation". Particle size analyses should be performed on composite samples obtained from previously designated sample areas, and that data, along with textural classification based on the analyses should be submitted for inclusion in the permit. In summary, based on an initial cursory review of the soils data it would appear that the sampled material has severe restrictions for use as a plant growth medium. However, more in depth review seems to indicate that suspect results were probably due to inappropriate and inprecise analytical techniques and incorrectly labeled parameter units (mmhos vs umhos). The Division will review these responses and if necessary require remedial actions (if any) be taken. For example, if the materials on site were found to be unsuitable, the operator may need to purchase (and bond for) replacement material. Surface Water and Groundwater Hydrology 1. Kaiser Coal Corporation needs to identify whether water rights for the North Fork of the Gunnison River and Hubbard Creek are still needed for current mine operations. Records of past consumption and an estimate of future water use will help P1LRD to confirm that no adverse impacts on downstream water users will occur as a result of current operations at the Somerset Mine. Also, provide documentation to MLRD of approval from U. S. Steel Corporation and/or Colorado water Resources Division for use of these water rights. Kaiser Coal Corporation needs to submit a reclamation plan in accordance with Rule 2,05.4 for the sewage leach field and water intake galleries along the North Fork of the Gunnison River. This may be included in the technical revision to be submitted to the Division. The reclamation plan needs to be approved prior to initiation of reclamation activities. This information could not be found in the application. The reclamation plan does not address how the degas wells Bear Creek are to be reclaimed. In addition the operator should describe how the reclamation cost estimate for the was calculated on Page E-14, in wells