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-. ,. Memo-Roger Funston February 22, 1980 Page -3- • i 3) Possible changes in groundwater movement, either from the presence of abandoned mine workings, subsidence, or both. 4) Following abandonment, underground working would slowly fill with water until some sort of equilibrium is reached. How long would this process take? MONITORING - 1) The mine plan monitoring program should be shown on map with a scale more suitable than that of mao III-II. 2) It is unclear if the applicant intends to monitor both alluvial and bedrock groundwater. Identify all ground- water monitoring points by aquifer. Monitoring should be provided for all six aquifers. 3) The groundwater monitoring program should include the monthly recording of water level. STREAM BUFFER ZONES - The application should request a variance from the buffer zone requirement. Discussion should include measures taken to protect the hydrologic balance of the Williams Fork River. ALLUVIAL VALLEY FLOORS - The application does not contain sufficient detail to allow the Division to make a formal alluvial valley floor determination, identify essential hydrologic functions, and make a determination on material damages. The applicant should provide further information as required under Section 785.19 of the proposed permanent regulations. The applicant should obtain a copy of OSM's draft technical guidance paper for Alluvial Valley Floor Identification and Study. In the meantime, we should identify both the Williams Fork and Yampa River valleys as probable alluvial valley floors. CUMULATIVE ASSESSP1ENT - Section 786.19(c) of the proposed permanent regulations requires "the assessment of the probable cumulative impacts of all anticipated coal mining in the general area on the hydrologic balance, ." At present, the Division does not have a sufficient data base to make this assessment. Therefore, in terms of hydrologic impacts I do not see any way that the Division can sign off under a "permanent program review" until we have reviewed Utah International's surface and underground submittals. Two other areas, approximate original contours and a stabilization plan for the Williams Fork River, has not yet been reviewed. I will provide you with that analysis early next week. Given the current state of the submittal (i.e. incomplete), the hydrology section will be rereviewed after the requested information has been received. I may have further questions at that time.