APPCOR10523

• Permit No: C1981044
• IBM Index Class Name: Application Correspondence
• Doc Date: 4/28/1981
• Doc Name: EMPIRE ENERGY CORP PRELIMINARY ADEQUACY REVIEW FN C-044-81
• From: MLRD
• To: EMPIRE ENERGY CORP
• Media Type: D
• Archive: No

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comma»ts contained in II. S. Section 3.4 - Ground water
Resources; I7.6. Section 3.5 - Surface l;a ter Resources;
II. 7, Section 3.6 - Alternate Water .Supply; and III.3.
Section 9.3 Protection of the Hydrologic Dalance (See
letter dated June 9, 1980 from Roger Funston to Steve
Self).
July 10, 1980; A Letter from Roger Funston and a memo
from me was sent to Empire Energy. In my memo, I stated
that the monitoring plan of May 16 would supply sufficient
information for deep aquifers, alluvium of the Williams
Fort, and Surface streams. Rowever, I re-emphasized the
need for ground water monitoring of the S'ampa River Valley
alluvium.
July 14, 1980: Steven Self sent a letter to Dave Shelton
detailing progress with the installation of ground water
monitoring e,•e11s. In this memo, Steven Self brought up the
problem of obtaining surface access to install the ground water
monitoring wells on surface land controlled by Colowyo Coal
Company. I was never made aware of this memo.
August 7, 1980: A meeting was held in the Divisions conference
room, with members of Empire Energy, Plineral Resources and
Engineering, Inc.; Mined Land Reclamation Division; and Ro4ert
Drogden present. The meeting covered alluvial valley floor,
ground water monitoring and subsidence questions. Darry Ferguson
of Mineral Resources and Engineering, Inc, commented that
Empire Energy does not need to moniCOr the alluvium of the
Yampa River Valley because Empire Energy will be grandfathered
out of Alluvial Valley Floor (AVF) monitoring and determinations.
Mined Land Reclamation countered with the fact that the
alluvial ground water monitoring is essential in assessing the
hydrologic balance of the area to be undermined and in assessing
the effects of mining on the hydrologic balance. Also Jerry
Zimpfer pointed out to Empire Energy that grandfathering does
not eliminate the A.V.F. performance standard requirements.
Empire representatives argued that the deep monitoring wells
would supply information on subsidence effects to ground water
system, The Division agreed that a properly installed and
monitored deep ground water wells would respond quicker to
effects of subsidence on ground water in t/re overlying
aquifers. The Division then asked Empire Eneryy if they had
installed thr. deep ground water monitoring wells agreed upon
by the Division on Afay 13, 1980. Empire replied that it
had not installed the wells because of access rights problems
with Colowyo Coal Company which owns the surface rights. Mined
Land Reclamation Division then stressed that Empire Energy will
not-have sufficient baseline ground water data and will not be
able to assess the impacts of mining on the hydrologic balance
until they: 1) install ground water monitoring wells; 2) begin
gathering ground water levels and chemistry data; and 3) perform
aquifer tests on the overlying stratum, Empire Energy stated
that they will continue to pursue acquiring access to the
Colowyo surface. The Division requested the Empire Energy keep
us updated on the progress in this matter.