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Mr. David Berry Novenber 24 , 1993 Page 4 Included with this submittal is a site by site sutmiary of the monitoring which was corclucted in 1992 aryl an explanation of why certain monitoring was omitted. CDVCC can normally begin monitoring in May. Mast of the roads OOVCC utilizes to conduct monitoring are not maintained aryl are in extremely poor condition. OOVCC must be cognizant of utilizing roads on private property only during periods when such use will not degrade the roads. One good, well- maintained road provides excellent access to the northeastern portion of the permit area. It is reasonable that monitoring in this area can in some years begin in April, however, in most years, roads will generally not became passable until sometime in May. OOVCC intended to initiate monitoring in May of 1992. Monitoring was initiated in May during 1990 and 1991 and had not been questioned previously by the Division. Between May 21 and May 31, 1992, over two inches of rainfall was recorded at the Orchard Valley Mine fan level precipitation gauge. S7na11 amounts of precipitation render the majority of roads used for monitoring impassable. 'IWo inches of precipitation occurring during the last third of May effectively closed the majority of roads utilized for monitoring during that period. As a consequence, the opportunity for May monitoring was missed at a majority of the sites and monitoring efforts were subsequently renewed in June. CDVCIC aalaiowledges that had hydrology monitoring been focused as the top priority work task during May, data could have been generated earlier in the ~mnth. However, several projects of more critical immediate importance to the Orchard Valley Mine were ongoing at this time which superseded hydrology monitoring in terms of priority. ODVCC was in the process of developing plans to mine Panel C. Panel C permitting was critical as mine development to the west pod had been delayed and immediately available coal reserves had been nearly exhausted. CL~VCC was in the process of responding to regulatory concerns identified during an oversight inspection on May 7, 1992. A violation was issued during the inspec.-tion which rerniired immediate abatement and follow-up permit revision work. Work entailing certification of the West Mine Fill was required at this time as well to avoid issuance of an additional NOV and the 1991 AHR was being finalized for submittal. COVCC was also developing Small Area F~cemption demonstrations which the Division had indicated a high degree of interest in resolving. In short, the resources required to address all these issues arri the hydrologic monitoring were not available. 'Ihe hydrologic monitoring is a very time intensive process. It typically takes 5 full days to Ooi[g~lete currently mrniired monitoring if r10 cmiq~lications arise. In light of the questionable utility of the majority of the hydrologic monitoring required, ODVCC opted to focus its resources and efforts on other matters. Sane data which was collecked during 1992 was omitted from the AHR. As the Division is aware, the hydrology database utilized by Orchard Valley has undergone total reconstruction over the past two years. Many bugs are left to be worked out and canissions will be addressed and corrected as soon as the system software is o~npleted and training is acacm~lished. ~VCC currently