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a <br />kerr coal company <br />su7fe 4D0 • three park central • 1575 Arapahoe • denvar, Colorado 90202.1303! 623-8377 <br />~II ~I~~I~~I~~~~~~~~ <br />~ sss <br />August 24, 1981 <br />RECEIVED <br />Mr. David Craig <br />Colorado Mined Land Reclamation Division <br />423 Centenial Building <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />Re: Comments on Overburden and <br />Water Chemical Analyses <br />Dear Mr. Craig: <br />AUG 2 6 1981 <br />MINED LAND RECLAMATION-COAL <br />COLO. DEPT. OF NATURAL RESOURCES <br />This letter is written in response to the request of <br />David Shelton to Colorado Coal Operators dated June 17, 1981, <br />regarding current chemical analysis requirements for over- <br />burden and water. <br />Kerr Coal Company ("Kerr") submits the following comments <br />for your consideration: <br />OVERBURDEN <br />Textural Analysis. In the past, the Division has <br />required coal operators to submit as part of coal mining <br />permit applications a textural analysis of the overburden <br />within the permit area. Because the required tests to deter- <br />mine overburden texture necessitates that the overburden <br />material be ground into small particles prior to testing, Kerr <br />submits that. the results of such an analysis are virtually <br />meaningless. The grinding process destroys the texture of the <br />material in a way which does not simulate the processes of <br />replacement and weathering under actual mining conditions. <br />Clearly the results of such an analysis may tend to suggest <br />potential textural problems when none, in fact, exist. Unless <br />and until a method for sampling overburden material is <br />developed which approximates the actual texture of the over- <br />burden under actual mining and reclamation conditions, Kerr <br />recommends that the requirement for overburden textural <br />analysis be eliminated. <br />