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Mr. Rick Mills -2- July 13, 1984 <br />The Division maintains that this stipulation, as presented in the Eagle <br />No. 9 Mine April 19, 1984 findings document, is valid and justifiable, <br />and should remain in effect. As it has been stated before, the Eagle <br />No. 5 and 9 Mines are located in a hydrologically sensitive area. <br />Existing or proposed mining has occurred or is projected to occur <br />beneath three significant alluvial valley floor areas (holding rivers, <br />saturated unconsolidated streamlaid deposits, and flood irrigated <br />agricultural activities) and three major sandstone bedrock aquifers. <br />Empire Energy Corporation has conducted an indepth analysis of projected <br />inflows to the mine workings, which is presented in the permit <br />document. This analysis is considered adequate and acceptable by the <br />Division for predictive purposes; however, measurement of bulk discharge <br />from the mine workings and comparing this to the projected inflow rates <br />is not sufficient in understanding of mining impacts on the hydrologic <br />balance in the area. Inflows to the mine workings are attributable to a <br />number of sources that are subject to change with time. Annual mine <br />inflow studies are the most effective, and in fact the only method by <br />which to determine the locations and temporal variations of water <br />inflows and water quality from individual areas within the mine <br />workings. This information can be used in conjunction with other <br />hydrologic monitoring data (spring flows, stream flows, alluvial and <br />bedrock water levels, and water quality information) to evaluate more <br />precisely how mining is impacting the hydrologic balance. This type of <br />evaluation can not be performed without mine inflow studies; therefore, <br />the Division feels that the annual mine inflow studies are an integral <br />component of Empire's overall hydrologic monitoring program. <br />Stipulation No. 4 <br />The response to this stipulation was submitted in a letter dated <br />February 14, 1984. The stipulation requested modifications to the <br />hydrologic monitoring program. These modifications and Empire's <br />responses are outlined below, in the same order as addressed in the <br />stipulation. <br />A. Empire has submitted a revised page IV-121a to include frequency of <br />monitoring and parameters as requested for mine water discharge. <br />B. As part of Empire's NPDES monitoring, they have committed to <br />submitting copies of quarterly NPDES reports to the Division and <br />will inform the Division of any request for NPDES monitoring <br />reductions. The pertinent verbage appears on revised page IV-121 a. <br />C. Several adjudicated springs were requested to be monitored for both <br />flow and quality. These springs are identified on Map III-14 as the <br />Haxton Spring I, and Lippard Springs I and II. Due to the low flow <br />conditions at the Haxton Spring I, as described on revised page <br />IV-121 a, Empire has requested that the requirements to monitor this <br />spring be discontinued. Due to the lack of sufficient historical <br />data on file for this spring, the Division at this time cannot <br />approve this request for deletion of monitoring. <br />