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Reclamation Liability Period, Kerr has demonstrated that the adequacy of the <br />groundwater monitoring program (Rule 4.05.13) has been satisfied. <br />In support of the above, following is an excerpt from the closing comments (in <br />Requirement "S ") of the DRMS' review memorandum of the Kerr 2010 Annual <br />Hydrology Report (AHR): <br />"The monitoring program is adequate. Based on data in the annual hydrology <br />report for 2010 and previous years, and as set forth above, the operator has <br />demonstrated that: the qualities and quantities of runoff without treatment are <br />consistent with the requirements of 4.05; the operation has minimized disturbance to <br />the hydrologic balance in the permit and adjacent areas; the operation has prevented <br />material damage to the hydrologic balance outside the permit area; and the water rights <br />of other users have been protected ". <br />A copy of the DRMS' review memorandum of the 2010 AHR is included with this <br />submittal. Also included is a listing of water analysis data collected during the ten <br />previous years. The data is also on file with the DRMS. <br />Given that Kerr has demonstrated that the hydrologic balance requirements <br />(Rule 4.05) have been met, that the water monitoring program (Rule 4.05.13) is fulfilled <br />and considering that the Loadout site, including the related former pond footprint, is <br />near completion of the approved reclamation requirements, Kerr believes that further <br />monitoring of the alluvial wells is redundant and unnecessary. <br />Accordingly and in accordance with Rule 4.05.13(3)(b), Kerr hereby requests <br />deletion of the water monitoring program pertaining to the alluvial wells, AP -1 and AP -2 <br />at the loadout site. <br />Following approval of this request to terminate the groundwater monitoring <br />requirements, in accordance with Rule 4.07.3 and in accordance with the approved <br />Permit Document, Kerr will remove the casings from the shallow alluvial wells (12 to 13 <br />ft depth), backfill the holes, seed the resulting disturbed areas with the approved seed <br />mix and hand rake the seeded surface as required. <br />In accordance with Rule 2.08.4, Technical Revisions, the following items are <br />enclosed with this submittal: <br />Enclosures: Three (3) copies each of the following: <br />• Technical Revision Form; TR -26; <br />• Narration of purpose of the Revision Request; <br />• Proposed Public Notice; <br />• Historic water analysis data (10 years), Tables 1 and 2; <br />• Revised Hydrologic Monitoring Schedule, Table 61 (for insertion in Exhibit 14 of <br />the Permit Document; <br />• Loadout Monitoring Stations Map, Map 2. <br />