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Mr. David Bea.-ry November 24, 1993 Page 2 established. In the recently acquired and permitted new lease area, q~~artarly monitoring of surface water features for one year was deemed sufficient to establish baseline data for these resairces. In contrast, the currently permitted ongoing hydrology monitoring program *~>;~~ monthly monitoring of all identified locations. A total of 98 sites required monthly monitoring during 1992. Of the 98 required monitoring locations, OOVCC believes sufficient justification exists to discontinue monitoring at 71 sites considering current mine activities and previously documented hydrology data. OOVOC further believes that justification exists to reduce the ra1~ired monitoring frequency from monthly to quarterly in the majority of instances. OOVOC asks the Division to consider the value of the data which was not collected during 1992 in azc~zing the civil penalty for this violation and stresses that the majority of the data which was missed is associated with sites that should be discontinued on the basis of their location >r relation to current or relatively recent mining activities. ODVCC also asks the Division to consider the fact that ample baseline data has previously been collected. More specifically, cOVOC asks the Division to be aware of the following observations. OOVCC will, as soon as possible, formally present a technical revision request to the Division to modify the hydrology monitoring program in accordance with these observations. Of the 27 ponds requiring monitoring in 1992, 10 are located >r areas which will not be impacted by mining operations urrier the current mine plan and 2 have been observed to have their dams breached since the inception of monitoring. An additional 11 are located in aryl adjacent to areas over the East mine which ceased activity in mid-1986 due to a mine fire. No impacts have been detected by the monitoring conducted at these locations since 1986 and no new activity has taken place in the East mine. Of the 27 ponds requiring tronthly monitoring during 1992, OOVCC believes 12 should be pernianently dropped from the program, 11 should be temporarily discontinued until such time as mining activities in the Fast mine are renewed, and 4 should continue to be monitored on a quarterly basis. Of the 29 springs requiri.rg monitoring in 1992, 11 are located in areas which will not to be impacted by mini.nq operations under the current mine plan and 2 consistently exhibit flows which are too insignificant to justify monitoring. An additional 12 are located in and adjacent to areas over the Fast mine which ceased activities in mid 1986 due to a mine fire. No impacts have been detected by the monitoring that has been condtncked at these locations since 1986 arcs no new activity has taken place in the Fast mine. Of the 29 springs requiring monitoring duri.rg 1992, OOVCC believes 13 should be pP*~*+p*+tly dropped from the program, 12 should be temporarily discontinued until such time as mining activities in the East mince are renewed, 3 should continue to be monitored on a quarterly basis, and 1 on a monthly basis.