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determining the impacts to the hydrologic balance. The quarterly field parameters are <br />important in monitoring the flow rete of the springs. The lack of the water quality and <br />quantity data leaves a hole in the analysis. <br />I agree with the proposed civil penalty. It represents low/moderate seriousness. <br />Fault <br />The proposed assessment comments that there was a change in the personnel conducting <br />monitoring at this mine. However, in the assessment conference, Mr. Mills seemed to have a <br />good understanding of the requirements of the monitoring plan. There was some ambiguity <br />regarding whether samples could be combined for springs in close proximity, but Mr. <br />Gorham did not include those sites in the NOV. Mr. Gorham and Mr. Mills will meet to <br />clarify when and where spoil spring samples will be combined. <br />Mr. Gorham expressed his frustration of not having all of the data available in order to do his <br />analytical review. The deadline was extended until May to allow CYCC time to figure out <br />their data base. After the data was submitted, the Division notified CYCC in August, 1994 <br />requesting the missing data. The letter was followed up by phone requests in September and <br />October. One missing sample was submitted in October. At that poim in time, Mr. Gorham <br />thought all the available data had been provided and he issued the NOV. For the abatement, <br />he allowed CYCC over a month to provide any more data or explanation they had. No data <br />was presented to the Division until the assessment conference. <br />Mr. Mills said they were still working out the bugs in the new database. He brought in a <br />number of data printouts for reference in the conference but, he was under the impression <br />that the Division already had this data. At that point it was decided that Mr. Gorham would <br />check the raw data submitted by CYCC to determine if it had been submitted. It had not. <br />There are several factors to take into consideration. First, CYCC did fail to collect full <br />suite analyses at two springs and the quarterly field parameters at six of the spoil springs. <br />Second, CYCC was not diligent in submitting the data to the Division. This may have been <br />partially due to the fact that CYCC was in the process of developing and figuring out a <br />recently installed complex database. <br />Based on the information presented in the conference I conclude that there was a lack of <br />diligence by CYCC in collecting all of the spoil spring monitoring data. Most of the data <br />was collected, except the eight points listed above which indicates CYCC was conducting <br />monitoring, they missed these occurrences. The record indicates CYCC was not diligent in <br />providing the data to the Division. In August the Division notified CYCC that data was <br />missing. Some of the data was available, but it was not submitted until the assessment <br />conference, four months after CYCC had fast been notified. I agree with the proposed <br />penalty. <br />Gc_x_xd Faith <br />There is no evidence of good faith. <br />