Laserfiche WebLink
INTRODUCTION <br />On June 30, 1993, representatives of the Office of <br />Surface Mining (Denver and Albuquerque offices), the <br />Division of Minerals and Geology, and Enron Corp. met to <br />discuss certain outstanding issues regarding the 1992 bond <br />release request submitted for the Meeker Area Mines (Permit <br />Number C-81-032). One of the issues discussed at this <br />meeting was the use of the Division's data which was <br />collected as part of the Phase II bond release approval <br />process. This letter will compare the data that was <br />collected by the Division with that collected by the <br />operator. In 1992, both parties quantitatively sampled <br />parts of the reclaimed Meeker Area Mines. The operator's <br />data were collected by Matthew S. Hayes of Hayes <br />Environmental Services (HES) between July 7 and 9 and are <br />summarized as part of the report entitled Meeker Area Mines. <br />Permit Number C-81-032. 1992 Vegetation Report. Phase II <br />Bond Release Request. The Division's data were collected on <br />July 13 and 14 and are described as part of Attachment 4. <br />Narrative Evaluation of Compliance. Although the following <br />discussion was not specifically requested of Enron Corp. as <br />part of the June 30, 1993 meeting, it is included in case <br />any doubt remains regarding how the two sets of data <br />compare. <br />DATA ADEQUACY <br />Page 15 of the Division's Guidelines for Compliance <br />states "The regulations require a demonstration that pre- <br />and post-mine vegetation communities and reference areas <br />have been sampled so as to obtain a statistically valid <br />estimate of the mean for particular parameters such as <br />cover, production and woody plant density. The Snedecor- <br />Cochran sample size adequacy formula is recommended by the <br />Division...." In 1992, the Division sampled only eight <br />points over the entire reclaimed Meeker mine site. The <br />sample adequacy calculation using those eight samples is <br />13.5, indicating that an adequate sample at the 90$ <br />statistical confidence level was not collected. As <br />demonstrated in Table 4 of the HES vegetation report, the <br />operator's data was collected in excess of adequacy (17 <br />samples collected vs. a sample adequacy calculation of 7.2). <br />Because the Division did not sample the mine site to <br />adequacy, their data cannot be used to refute the operator's <br />data. <br />