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Mr. Rick Mills -3- July 13, 1984 In addition to the three adjudicated springs discussed above, several other springs are included in Empire's hydrologic monitoring program. These are located on Map IV-13 and are identified as the North, East and South Springs, and the Williams Fork No. 1 Strip Pit discharge. On pages III-55 and 56 of the permit document, Empire has proposed to cease monitoring the North, East and South Springs. On page 4 of the 1983 Annual Hydrologic Monitoring Report it is stated that monitoring of the East Spring was terminated in November 1983 and on Table 24 of the report it is stated that monitoring of the South Spring was terminated in November 1983. Data on these springs is missing from the 1st Quarter 1984 Hydrologic Monitoring Data submittal. No formal written approval for any spring monitoring reductions or terminations has been granted by the Division. In order to clear this matter up, I suggest that Empire submit a technical revision to the permit (as is required under Rule 1.04(136)), requesting the monitoring reductions or deletions they feel are warranted. Prior to this submittal, I suggest we discuss the proposed changes. Also, it is somewhat unclear from the information on file whether or not the North Spring and the Lippard Spring I share the same source, and at what location this spring or these springs are being monitored. This item needs to be clarified by Empire. D. This request was for quarterly submittal of all hydrologic monitoring results. Revised page IV-121b reflects the commitment by Empire to submit all hydrologic data on a quarterly basis. Stipulation No. 5 This stipulation directs Empire Energy Corporation to submit annual hydrologic reports. The first such report covering the calendar year 1983 was submitted on time. Review of this report will be discussed in a forthcoming letter. Stipulation No. 6 This stipulation requires Empire Energy Corporation to submit a report on all overburden proposed to be used as plant growth media. Empire has submitted a report for overburden from the 5A Portal area. All items within the stipulation have been addressed in the report. Samples from four locations were analyzed at 6-inch depth increments down to 36 inches. Results of these analyses indicate that, except for nitrogen and phosphorus levels, the overburden material sampled would be suitable as a plant growth medium. Nitrate nitrogen levels are somewhat low (mean value for all samples = 3.3 ppm); however, given the organic matter concentrations of between 6 and 29%, this may not be a significant problem. Phosphorus levers were all less than 2 ppm in the samples analyzed. Empire has stated in the report that at the time of seeding, 30 lbs/acre of P205 will be added to the material. The response to this stipulation is adequate.