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C crp~us <br />"`~ Yampa Valley <br />Cyprus Yampa Valley Coal Corporation <br />29587 Routt County Road N27 <br />Oak Creek, Colorado 80467 <br />303.879-3800 <br />December 7, 1994 <br />Kent Gorham ~EDEIVED <br />Environmental Protection Specialist n~C, <br />Division of Minerals and Geology ~C 13 1994 <br />Office of Mined Land Reclamation <br />DenverheColoradoe802p2oom 215 ~mislono~Mme~atsa~epjo9y <br />RE: NOV C-94-029 <br />Permit No. C-81-071 <br />Dear Mr. Gorham: <br />A bit of confusion resides over the submittal of the abatement <br />information for the above referenced NOV. Colorado Yampa Coal <br />Company did not willfully or knowingly fail to comply with the <br />abatement measures. The data that is alleged to be missing cannot <br />be collected due to the passage of the required monitoring period. <br />The delay upon supplying the explanation for missing the sampling <br />is based upon a prior discussion in which I presented Colorado <br />Yampa Coal Company's position on the sufficiency of the spoil <br />spring sampling. It was my understanding that the Division would <br />consider the verbal argument presented for not obtaining samples <br />from selected spoil springs. <br />The confusion over the spoil spring sampling program resides in the <br />fact that CYCC previously did extra sampling on some of the springs <br />and submitted the data. However, it is CYCC's understanding that <br />only a composite sample is required from the A, B, C, and is <br />obtained at site D. This understanding was discussed with prior a <br />CYCC employee responsible for conducting the sampling. This <br />employee indicated that this topic had been discussed previously <br />with the Division and it was agreed that CYCC was conducting its <br />sampling program in accordance with its permit. The field <br />parameters were obtained for the individual springs and the <br />composite was taken from site D. This data was submitted <br />previously to the Division. Based upon this CYCC believes that it <br />complied with the requirements of the permit. The schedule <br />presented on page EX 8-8 provides for composite sampling. <br />If there are further questions, please contact me at your <br />convenience. <br />Since~~ <br />i~~~~ <br />Richard Mills <br />Manager, Surface/Environment <br />ale:c.\x'pSi\prrm~94\nov94-029.cyc <br />