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.~. Mr. Kent Gorham November 16, 1994 Page 2 respect to their proximity to mining activities with the potential to generate detectable changes in water quality. Limited water quality monitoring was conducted at selected locations at frequencies sufficient to detect arri docimient potential mining impacts and take corrective actions if necessary. No apparent significant water quality impacts were documented. In 1993, COVCC fulfilled its contiltuing obligation to protect the environment and the interests of both public aryl private entities within aryl adjacent to the Orchard Valley permit area by conducting responsible hydrologic monitoring to detect potential mining related impacts. In an ongoing effort to ~Y~m~ze the effectiveness of limited r~~**p~ arri maintain the economic viability of the Orchard Valley Mine as an operating entity, superfluous monitoring requirements were not addressed in a manner wholly wnsistent with the specifications of the permit document. During 1993, the wntinuation of an essentially procedural or administrative violation may have occurred insofar as the permitted monitoring program was not formally changed via the technical revision process prior to 1993 and the monitoring ccmq~leted in 1993 did not conform to the program specified in the permit. However, with respect to the subsequent monitoring requirements approved by the Division via TR24 following the tharrnx~n review of the overall program, monitoring conducted in 1993 closely mirrored the current program requirements and was therefore consistent with and adequate to meet the basic intent of the monitoring program. In accon9ance with the abatement „wa~,res required for NOV C-94-032, the following information provides written docwrentation of all additional available data and a site by site explanation as to why specified samples or site visits as detailed in your letter of the 17th were not o~q~leted. North Fork Alluvial meter Monitorira Wells MWO1, MW02, MW03: ZYne October visit to these sites was inadvertently overlooked however all other rgniired visits were completed during the remaining eleven (11) months of the year. As conq~ared to the current monitoring requirements, three monthly water level omissions occurred during 1993. Fast Roatcap Creek Colluvial Monitoring Wells SMOS, SM06, SM07, SM10, SM11: All of the above noted wells were located outside of the potential subsidence zone during 1993. ~~n.o '^tial water quality database information had been established for each of these sites prior to 1993. Since monthly water level aryl field parameter data collected beginning in May gave no indication that impacts of any type might be occurring, only one additional water quality sample was collected for docwnentation purposes during 1993.