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rrr. Kent Gorham August 2, 1994 Page 3 states that subsidence will not cause material damage in licit of the specific conditions, plans, and control ~avTMPa PYICti}p at Orchard Valley. WVOC believes this permit language is consistent with the reyulations. Fifth, the subsidence study caorducted for Orrharrl Valley aryl presented in Volume 3 of the permit doa~ent is based upon conservative assumptior~ in every inatanoe. Insofar as surface water r+e,otu~oes sudr as ponds are ~~, the study concludes that only those located over less than 800 feet of overburden are at risk of being affected by subsidence as surface cracks are not anticipated to propagate through more 500 to 600 feet of overburden under normal conditions. 4he mire plan developed for Orchard Valley includes established buffer zones in those areas of less than 800 of overbuitien. No subsidence inducing mining is widertaken in these areas. Rhe surface water resources located outside of the buffer zones are pre~~ed to be prcotec.'ted by virtue of the existing overburden. Zhis presumption is continually verified by hydrology monitarirrg acted at all ponds within the accepted anglerof-thaw, regardless of overlxmden depth, sufficient to detect any significant long term disnrption to the hydrologic function and pattern of particular resouunes located outside the buffer zones. Lastly, after further reviewing the permit doamier~t, OOVOC believes much of the information requested by the Division with regard to a specific inventcry of ponds acrd a diswssion of potential imlaacts already Tr~ars in the permit under Sections 2.04.7, 2.05.6(3) (iii) aryl 2.05.6(3) (iv) . In lic~st of this information, and the required de*p*+~i*ution of probable hydrologic consequences corntaired in the regulations, OOVOC questions the necessity of essentially restating this informatia~n elsewhere within the permit document and requests the Division to review these portions of the doampnt. A simple cross-referencing of permit text may be sufficient to meet the regt~inas~ant~ of liules 2.05.6(6) (a) and 2.05.6(6) (b) in the event these regulations are demorLStrated to be applicable to ponds with man-made c+mtv~ntcmer,tc, Please contact IDe if you have arty questions rxarx9imr this submittal. Q7VQC looks forward to the receipt of the requested doa~entation arxi will evaluate any information provided as soon as passible. In additien, specific written requests to amend the permit in aooordance with the doc~.ntation provided would be most beneficial to initiate the process. 'II~ank you for your continued cooperation in this matter. ~~~r Karl C. Koehler FhVis~orrmental Specialist /kck cc: Mr. David Berry, CDN~ CDMG General Oarrespondenoe file