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7. The post reclamation drainage plan isn't addressed specifically by <br />exhibits, maps, or discussion. Kerr Coal Company has committed to <br />leaving the existing drainage system intact until revegetative growth <br />reaches acceptable levels. Apparently this implies that this final <br />system will be used in a unmodified state to contain runoff during this <br />stage of reclamation. The staff feels that a specific section should be <br />devoted to an outline of the reclamation plan's drainage system to assure <br />that the existing drainage system effectively services the particular <br />needs of the final reclamation phase. [Rule 2.05.6(3)(a)]. <br />Water Rights and Replacement - Rules 2.04.7(3), 2.05.6(3)(a)(ii), 2.07.6(2)(c) <br />an <br />8. Please prepare a listing of water rights (surface and ground water) <br />located within one mile of the permit area on the west and south and <br />located between the permit area and the Canadian River on the east and <br />north. In addition, prepare a listing of water rights located within one <br />mile of the loadout. Please map this information. [Rule 2.04.7(4)(a) <br />and Rule 2.04.7(4)(f)]. <br />No description has been included in the permit application concerning how <br />augmentation water can be supplied to impacted adjacent water users. <br />Kerr Coal should prepare a discussion on this subject outlining the <br />method of transporting water from their water rights' sites to the <br />impacted water user. [Rule 2.05.6(3)(a)(ii) and Rule 4.05.15]. <br />10. Please submit documentation of augmentation plan approval, to complete <br />Exhibit 25. If this plan was modified as part of the approval, please <br />submit the revised plan. <br />Topsoil - Rules 2.04.9, 2.05.3(5), 2.05.4(2)(d) and 4.06 <br />11. Final reclamation of Pit 1 requires subsoil from Pit 3 to ensure adequate <br />depths of non-toxic (low SAR) soils. Given the current production rate, <br />contemporaneous reclamation would not be achievable at Pit 1 if material <br />from Pit 3 is required. Please propose a modified soils handling plan <br />which addresses the source of other subsoil material for Pit 1. <br />tion - Rules 2.04.10, 2.05.4(2)(e), 4.15 and 1.48(4)(1) <br />12. Rule 2.05.4(2)(e)(iii) requires that the permit application address the <br />methods to be used in seeding reclaimed areas. The narrative does not <br />clearly delineate how seeding of the perennial seed mix will be <br />accomplished or whether some broadcast seeding will be necessary. While <br />page 780-78 fff does contain a note that drill seeding will be used <br />always, this sentence is contained within a paragraph devoted to the <br />seeding of annual mulch species. Furthermore, if Kerr anticipates areas <br />where those annual mulch species cannot be drill seeded, we assume <br />perennial species will not be able to be drill seeded there either. <br />Please clarify this issue. <br />