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Interoffice <br />MEMORANDUM <br />to: Ron Cattan~yM1`'/~ <br />from: Kent Gorh"" ' <br />subject: CV-2002-008, Golden Eagle Mine, #C-81-013 <br />date: July 22, 2002 <br />Please find attached a letter (Exhibit A) concerning Notice of Violation CV-2002-008 issued to Basin <br />Resources, Inc. The operator has requested vacation of four of six paints of the violation that was issued <br />this month for failure to conduct hydrologic monitoring in accordance with the approved plan. <br />The operator addresses six points in the letter (Exhibit A). They do no[ challenge points #1 and #2. They <br />do however challenge points #3-6. The Division agrees with the rationale addressed in point #3 and <br />concurs with the request to vacate this portion of the NOV. The NOV has been modified accordingly to <br />exclude this portion of the NOV. <br />Regarding points #4-6, the Division does not concur with the operator's request. The operator contends <br />that equipment and circumstances, caused by the gas company who attempted to use the ventilation shaft <br />(monitoring well) to extract methane gas, prevented the mine from conducting required sampling activities. <br />The Division believes that measures to ensure that the site could be used for gas extraction and water <br />monitoring are the responsibility of the coal operator. Basin Resources clearly understood that these sites, <br />although sold to the gas company for methane extraction, were included in the water monitoring plan. The <br />operator states [hat the gas company was contacted during the water year about the problem but apparently <br />did not follow-up with the gas company to ensure that changes were made to allow water sampling. The <br />2001 water year was the first year that a water sample would have been available for analysis to determine <br />quality and potential impacts of the flooding of the mine workings. At this time the Division has not <br />reviewed any sampling results for the mine water, even though flooded areas could have potentially been <br />sampled over 19 months ago. <br />Based on the information supplied by the operator, the Division supports vacation of point #3 of the NO V <br />but not points #4-#6. <br />CC: David Berry <br />Dan Hernandez <br />