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~.. ^~ Mr. Self June 9, 1980 Page 3 indicated that no prime farmlands existed within the permit area, this section was found to be in compliance with the final regulations. III. Operations and Reclamation Plan (Section 4 of the application) 30 CFR 784 - State Equivilent Proposed Rule 2.04. 1. Section 4.1 - Operations Plan. This entire section is in compliance with the final regulations. 2. Section 4.2 - Reclamation Plan. This entire section is in compliance with the final regulations with the exception of Section 4.2.5 - Reference Areas. Prior to approval under the final program, the applicant will need to demon- strate that [he reference area currently selected reference all different vegetation types and significant environmental variables, are representative of these various conditions and will allow for rigorous statistical comperison in judging the success of revegeta- tion as specified in the final regulations. 3. Section 4.3 - Protection of the Hydrologic Balance. Section 4.3.3, the sediment control plan was found to be in com- pliance with the final regulations. The remainder of Section 4.3 was only reviewed with respect to the interim regulations. The yroundwater monitoring plan is still under review and the results of this review with respect to compliance will be forwarded to you when available. The staff geo-hydrologist has previously expressed his concerns to Darry Ferguson with respect to the placement of wells in the alluvial monitoring program for the Williams Fork River alluvium. As previously mentioned, the Division will need to review the results of the hydrologic monitoring program before being able to make determinations of compliance under the final regulations with respect to groundwater and surface water control and probable hydro- logic consequences. At this point in time, there are no well defined criteria for making determinations of cumulative hydrologic effects; when such criteria becomes defined, they will be applied to the review of this application during the re-permitting process. 4. Section 4.4 - Post-mining Land Use is in compliance with the final regulations. 5. Section 4.5 - General Facilities Plan is in compliance with the final regulations. 6. Subsidence Control Survey. No finding of compliance with final regulations was made with respect to the subsidence control plan. This section will be revisited during the re-permitting process. 7. Protection of Fish and Wildlife is in compliance with the final regulations. 8. Section 4.8 - Transportation Facilities This section of the application was only reviewed with respect to interim regulations. At the time of re-permitting under the final program, the requirements of 30 CFR 784.24 (State equivilen[ proposed Rule 2.05.3(3)), will need to be addressed (specifically, specifica- tions for each road width, road gradient, road surface etc.).