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- ~ ~ III IIIIIIIIIIIIIIII <br />c~~us <br />Yampa Valley <br />Cyprus Yampa Valley Coal Corporation <br />29587 Routt County Road s27 <br />Oak Creek, Colorado 80467 <br />303-879-3800 <br />October 19, 1993 <br />'~ECCIVE <br />ocr 21 799:; <br />Kent Gorham <br />Reclamation Specialist <br />Division of Minerals and Geology - '`='~ ~" ~ ^e~z's & ~ <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Re: Information Pertainino to Assessment of Violation; NOV C-93-137 Permit C-82-056. <br />Foidel Creek Mine <br />Dear Mr. Gorham; <br />The following information is being provided for inclusion into the penalty assessment process <br />for the referenced Notice of Violation. Please forward a copy of this information to the <br />Assessment Officer reviewing this NOV. <br />DMG Issue <br />1) Baseline data for lines A-A' and B-B' was not collected one month prior to the <br />commencement of longwall mining as required by your approved permit, and Rule <br />2.05.6(6)(cl(DI <br />TCC Resoonse <br />The Senior Engineer in charge of subsidence monitoring, Mr. Collin Stewart, interpreted the <br />referenced items to mean "within 30 days", rather than "30 days prior" as the Division has, <br />resulting in the current issue. <br />According to Mr. Stewart, one should ideally complete baseline surveys as close as possible <br />to the start of active subsidence, thus providing a minimal opportunity for other surface <br />activities to impact the subsidence baseline. According to Mr. Stewart, the key technical <br />requirement for baseline data are the monument elevations prior to the start of subsidence, <br />and the baseline monitoring which was conducted at the Foidel Creek Mine satisfies this <br />technical requirement. <br />DMG Issue <br />2) One week of data collection was not done between 12/22/92 and 1/7/93 (15 days) <br />