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III IIIIIIIIIIIII III 999 C c~RUs ~ Orchard Valley Cyprus Orchard Valley Mine P.O. Box 1299 Paonia, CO 87428 Phone: 303-527-4135 Fax: 303-527-2234 July 14, 1994 RECEIIiED Mr. Steve s. shuey ~~~ 18 19~ Environmental Protection Specialist Colorado Division of Minerals and Geology ~~~'is:on of Minerals ~, ~eo;cey 1313 Sherman Street, Room 215 Denver, CO 80203 RE: PF~D:T NO. C-81-038; MINCQt REYISI@I 99-99; IDEN1'IFICATIGAI OF IIT~STS UPDATE Dear Mr. Shuey: In response to the adequacy review for MR-94 and the specific concerns/questions identified by Christine Johnston in her memo of July 5, 1994, Cyprus Orchard Valley Coal Corporation (CDVCC) sulxnits the following information. The responses correspond to the numbered cmmnents in Ms. Johnston's memo. 1) Revised duplicate copies of permit page 2.03-3 are submitted herein which reflect the information provided in the cover letter of the original MR-94 application. Revised lists of changes are provided as well. Also enclosed is an officially signed and sealed "Certificate of Assistant Secretary" dociunenting the specified merger per Ms. Johnston's request 2) The percentage of ownership previously reported for CbVCC did not change as a result of the merger. In accordance with Ms. Johnston's request, the cxmership of ~VCC by Cyprus Amax Coal Company, Mitsubishi Corporation, and Samsung Co., Ltd. is defined on the revised copies of page 2.03-3 to consist of the indicated percentages of co~mnon share ownership. 3) The relationship between Amax Energy Inc. and Cyprus Amax Minerals Company is depicted on pages 3 of 52 and 6a of 52 of the revised Part 2.03 Appendix 1 pages subnitted with MR-94. As these pages indicate, Cyprus Amax Minerals Company is wholly owned and subsidiary to Amax Energy Inc.. 4) The corporate tree in the permit is intended to depict ~VCC's relationship to other entities with an ownership and control link to Cyprus Amax Coal Company and it's parent companies. As recently established via the Attorney General's opinion, neither Samsung nor Mitsubishi exhibit ownership and control over Orchard Valley. Therefore and purposely, neither company is identified in the corporate tree referenced by the Division. These companies are identified as part owners of Orchard Valley elsewhere in the permit in accordance with the applicable regulations. 5) A second officially signed and sealed "Certificate of Assistant Secretary" docwnenting the resignations of the appropriate individuals is herein provided in accordance with Ms. Johnston's request.