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r <br />~! <br /> <br />Mr. David Craig <br />Colorado Mined Lartd <br />August 24, 1981 <br />Page 2 <br />Reclamation Division <br /> <br />Boron. Kerr submits that dangerously high concentrations <br />of bores n overburden typically occus only in desert areas <br />where annual precipitation is less than eight inches. <br />Consequently, the Division should require overburden to be <br />analyized for boron only in desert areas. The State of <br />Wyoming currently requires analysis of boron only in such <br />areas; the Division should adopt a similar standard. <br />Potassium. Empirically, few if any areas in the Western <br />United States have been found to contain deficient quantities <br />'- of potassium for successful plant growth. Further, no <br />published guidelines for mining have identified toxic levels <br />for potassium. Consequently, Kerr recommends that the <br />Division eliminate potassium as a required chemical parameter. <br />Selenium. The presence of high amounts of selenium can <br />be readily determined by the presence of primary selenium <br />indicator plants. The Division should require an operator to <br />test for selenium in overburden only in those areas where the <br />presence of selenium is indicated by the plant life. For <br />example, since no selenium indicator plants exist in North <br />Park, Colorado, the Division should not require operators in <br />North Park to test for selenium. <br />Sulphate and Sulphur Forms. Since no coal mining areas <br />in the Western United States have identified sulphur leaching <br />as a potential problem, the Division should not require <br />chemical analyses of sulphate or sulphur forms. <br />Iron, C.E.C., Arsenic, Vanadium, and Chloride. Since no <br />suspect levels have been established or iron, C.E.C., <br />arsenic, vanadium, or chloride, Kerr submits that the Division <br />should not require analyses for these parameters. Clearly in <br />the absence of an established suspect level, the results of <br />such analyses are largely meaningless. <br />WATER <br />Boron. See previous comment under "Overburden" <br />Potassium. See previous comment under "Overburden". In <br />addition, si ce potassium leaching is only a potential concern <br />to ground water quality in areas with very high precipitation <br />and coarse soil texture, analysis for potassium should not be <br />required of operators in Colorado where high precipitation <br />does not occur and coarse soils are uncommon. <br />