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in the past and seeded recently to pasture grasses including intermediate <br />wheatgrass and timothy. Due to the age of the stand, annual weeds were <br />quite numerous. Based on the water level information and vegetation <br />observations which indicate the presence of subirrigation, the Division <br />concludes that the alluvial body in question is an alluvial valley floor. <br />Information concerning significance of the AVF to farming has not been <br />provided. Therefore, the Division will proceed by assuming the area is <br />significant and will make the three required AVF findings. <br />1. The proposed mining operations would not interrupt, discontinue, or <br />preclude farming on the alluvial valley floor. <br />Proposed mining activity would not directly impact any portion of the <br />AVF; as it is outside of the proposed Foidel Creek Mine Permit Area <br />and would not be undermined or disturbed by proposed surface <br />facilities. <br />2, The proposed mining operations would not cause material damage to the <br />quantity and quality of surface and ground water that supply the <br />alluvial valley floor. <br />Since this area was designated an AVF on the basis of subirrigation, it <br />is necessary to maintain the quantity and quality of water which supplies <br />the alluvial ground water system. <br />In the findings previously issued by the Division for the Foidel Creek <br />Mine (pilot project) in 1983, it was projected (based on information <br />available at that time that concentrations of dissolved constituents such <br />as sodium, sulfate, iron and TDS would increase in the alluvial ground <br />water. This effect was predicted based on the assumption that Foidel <br />Creek surface waters affected by mine water discharge would recharge the <br />alluvium, <br />However, data from a recent survey of the stream channel through the <br />alluvial body (Application Table 68) indicate the deposits underlying the <br />channel are clays and silty clays with very limited permeability. The <br />applicant has presented evidence that, due to the limited permeabilities, <br />recharge of the alluvium by Foidel Creek would be insufficient (5 x <br />10-4 gal/day/sq.ft, of channel) to provide enough water to support <br />subirrigation. Evidence indicates that the alluvium in the vicinity is <br />recharged from upper Williams Fork sandstone units which occur 10-20 feet <br />below the valley surface. As result, alluvial waters would not be <br />impacted by the increased levels of dissolved constituents in Foidel <br />Creek resulting from high TDS mine water discharge. <br />3. The proposed operation would preserve, throughout the mining <br />operation, the essential hydrologic functions of the alluvial valley <br />floor. The essential hydrologic functions for this alluvial valley <br />floor have been identified as the capacity to support subirrigated <br />-26- <br />