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Mr. David R. Gossett <br />March 24, 1988 <br />Page Three <br />3. Table 61 (b) indicates that aluminum is a required parameter for <br />the mine area surface water sites, but the lab analyses do not <br />include aluminum; please explain this discrepancy. Aluminum <br />does not appear to have been removed from the mine area surface <br />water monitoring program by the September 25, 1981 minor <br />revision which reduced the required monitoring parameters. <br />4. Dissolved oxygen is another parameter which is required by <br />Table 61(b) but appears not to be monitored by Kerr Coal Co. <br />Again, I cannot find documentation to show that dissolved <br />oxygen has been removed from the monitoring program. <br />The drainages within the mine area do not appear to have <br />flowrates capable of supporting fish populations. A minor <br />revision could be submitted to delete dissolved oxygen from the <br />monitoring program. <br />5. Table 61 (b) indicates that full-suite chemical analyses will be <br />conducted bi-annually for selected surface water monitor <br />stations. Only one full-suite analysis was submitted or was <br />illegible for sites 327 and 306. Please resubmit the lab <br />reports for these sites or indicate why the required monitoring <br />frequency was not met. <br />6. Please explain why at various times water flow is recorded at <br />the Bush Draw downstream monitoring site (306) when on the same <br />day no flow is recorded at the Bush Draw upstream monitoring <br />site (314). An estimate of water flow is important in <br />evaluating water quality data. <br />Soil Moisture Sampling <br />The permit text and Kerr Coal Company's response to Stipulation <br />~Y2 (dated October 21, 1981) both state that soil moisture <br />sampling will be conducted twice per year at facilities <br />installed in the flood plains of Sudduth Draw, Bolton Draw, the <br />Canadian River, the Illinois River, and undisturbed and <br />reclaimed areas using a neutron probe instrument. The results <br />of any soil moisture testing conducted during 1987 were not <br />included in the AHR. Please clarify the status of the soil <br />moisture tests. <br />