ENFORCE32206

• Permit No: C1981038
• IBM Index Class Name: Enforcement
• Doc Date: 11/18/1994
• Doc Name: PN C-81-038 NOV C-94-032 1993 HYDROLOGY MONITORING
• From: CYPRUS ORCHARD VALLEY
• To: DMG
• Violation No.: CV1994032
• Media Type: D
• Archive: No

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999
C c~~us
~ Orchard Valley
November 16, 1994
Nr. xem Gorham
Reclamation Specialist
Division of Minaras aryl Geology
1313 S71e~*+ Street, Roan 215
Denver, CO 80203
Cyprus Orchard Valley Mine
P.O. Box 1299
Paonia, CO 81428-1299
Phone: [phone]
Fax: [phone]
RECEIVED
NOV 18 1994
Division of Minerals & Geology
RE: PFSII~T NO. C-81-038; Ii7V C-94-032; 1993 H7~(II,OCY lII~II.'1CRII~
Dear Mr. Gorham:
In response to the abatement regl,;ramantg of NOV C-94-032 and the specific
monitoring omissions rated in yarn letter dated October 17, 1994, COVCC is
submitting the following information. OOVOC respectfully reque`,-ts the Division
to consider the following informatiaai in evaluating this violation.
4lre majarity of omissions noted far 1993 in your letter of the 17th are
associated with sites and frequencies no longer required within the monitoring
program. As you are aware, technical revision 24 drastically reduced both the
number of sites r~~ i rim monitoring and the frequency of r?~ ~ i red monitaring
visits. Zhe reductions were formalized and approved in the permit docwmnt
following a c~opetative and thorangh site by site evaluation conducted by CDVCC
and the Division during the TR24 process. During 1993, COVCC was well aware that
substantial justification existed to warrant the significarnt reduction of the
hydrology monitoring pxzz~am. iris ~ shied fran COVCC's familiarity
with the mine's spatial aryl tempozal relationship to the monitoring network, from
OOVOC's familiarity with prceviously wllected data, from ODVOC's familiarity with
the nature of documented and arrticipated impacts to water resources within the
permit area, arri from informal dicn,taions with the Division reg~~i*g the
readily apparent unneoessaty nature of a lan7e segment of the monitoring program.
As a result, OOVCC in 1993 primarily e~hasizgl the monitaring of physical
impacts at locations within the reasonably projected potential area of influence
of the mine. This monitoring was conducted at frequencies sufficient to detect
arri docimlent potential mining impacts and take corrective actions if necessary.
No apparent physical impacts ar irrnrnilwr hydrologic patterns were observed.
Substantial baseline water quality data had been compiled at virtually every site
o®prisirg the Orchard Valley monitoring network. Daring 1993, water quality
sales were not wllecked, ar were not collected at the permit specified
frequency, from those locations whose status had not changed recently with