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iii iiiiuiinm iii <br />999 <br />STATE OF COLORADO <br />MINED LAND RECLAMATION DIVISION <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />303 866-3567 <br />FAX: 303 632-8106 <br />June 14, 1991 <br />Mr. Hrent C. Anderson <br />Parcel, Mauro, Hultin & Spaanstra <br />Suite 3600 <br />1801 California Street <br />Denver, Colorado 80202 <br />RE: Grassy Gap Mine (# C-81-039) <br />Dear Mr. Anderson: <br />of ~o~ <br />~~'.- qy$ <br />H`~ [s~~j <br />~ o <br />+~"" <br />'rave <br />Roy Romer, <br />Govemar <br />Fretl R. Banta, <br />Division Director <br />After reviewing your letters of May 6 and May 20, 1991, MLRD's Notices of <br />Violation Numbers C-91-002 and C-91-003, OSM•a Ten Day Notice Number <br />X-91-02-116-4-TV-3, and the June 26, 1990 Agreement between the MLRD and the <br />Rockcastle Company, ae well as conferring with the MLRD inspector, I am denying <br />your request for vacation of those NOV's. <br />In Section II of your May 20th letter, you note that Rockcastle has <br />substantially complied with requirements associated with sediment pond <br />monitoring. Although Rockcastle had ACZ Engineering perform engineering <br />observations of the impoundments and prepared a report discussing structural <br />weaknesses and erosion and sediment levels of the ponds, it was not submitted <br />as the semi-annual pond inspection report and was not retained with the records <br />at the site. It was an engineering response to paragraph III(2) of the June <br />26, 1990 Agreement. <br />You also noted that NOV C-91-002 incorrectly referenced pond 1. The Division <br />agrees that this was incorrectly referenced. <br />Finally, in Section II you maintain that the NPDES sampling performed during <br />1990 constitutes substantial compliance with the monitoring required by the <br />permit. Rockcastle's NPDES sampling is not the subject of NOV C-91-003. The <br />hydrologic monitoring plan requirements were imposed on the company through <br />Technical Revision 2 approved September 4, 1986. This plan requires a <br />different frequency of monitoring at six locations when operations are <br />occurring at .the site than when the site is inactive. Rockcastle was operating <br />as an active mine when they started performing earthwork at the site, and did <br />not perform the required ten field samples, nine full suite samples, and a <br />spring and seep survey in 1990. <br />