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NOV C-85-012 - Foidel Creek - 2 - March 7, 1985 <br />The Division feels that seriousness of an administrative violation <br />should be based in part on the costs saved in not complying with the <br />requirements. The following laboratory costs were considered under <br />this Category: <br />Analysis <br />Parameter Cost* <br />Total Cost <br />Missing of Missing <br />Analyses Analyses <br />NH3 $ 7.00 1 $ 7.00 <br />TDS 7.00 1 7.00 <br />HC03 2.50 1 2.50 <br />Ca 4.50 1 4.50 <br />Mg 4.50 1 4.50 <br />NOg 8.00 1 8.00 <br />POg 7.15 3 23.25 <br />Na 6.25 1 6.25 <br />S04 8.00 1 8.00 <br />As 12.50 3 37.50 <br />Diss. Fe 4.50 1 4.50 <br />Diss. Mn 4.50 1 4.50 <br />Hg 18.00 3 54.00 <br />Cd 9.00 3 27.00 <br />Se 18.00 3 54.00 <br />Zn 4.50 3 13.50 <br />$ 266.00 <br />*Colorado Dept. of Health Price List for Govt. Agencies <br />Enforcement was probably not obstructed to a significant extent by the <br />failure to monitor mine water discharge as required, since the water is <br />routed through a sediment pond and monitored when discharged. The mine <br />discharge monitoring is necessary primarily to verify projections made <br />by the operator in the probably hydrologic consequences section of the <br />permit application. <br />A $266.00 seriousness component is proposed for Item 1, based on the <br />savings the operator incurred by failing to obtain the required <br />analyses. <br />With respect to Item 2 of the NOV, stipulation 4 to the September 4, <br />1984 technical revision approval required quarterly analyses of 25 <br />parameters and submittal of analyses to the Division on a quarterly <br />basis. The first set of analyses was to be obtained prior to any <br />placement of mine waste in the Area 2 Pit. The stipulation yas deemed <br />necessary by the Division in order to monitor the impacts of <br />underground development waste on ground water quality. The waste is <br />being placed in contact with standing water in the Area 2 pit. <br />