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iii iiniiiiuiii iii 999 Interoffice MEMORANDUM to: Janet Binns from: Kent Gorham ~~ subject: 1998 AHR, Eckman Park, #C-81-071 date: August 2~, 1999 I have completed my review of the 1998 Annual Hydrology Report for the Eckman Park, Mine 1, and Mine 2 operated by Colorado Yampa Coal Company as requested in your memo dated June 22, 1998. Overall, most sites were visited in accordance with the approved monitoring plan. However, the fall semi-annual visits to three spoil wells, 026-SP-1, 026-SP-2, and 026-SP-3 were missed. Other noted problems are as follows: ^ Most datums listed in the data tables do not match the datums on the site location map ^ Wells 94M001 and 94M002 aze not spotted on the map ^ Spoil well graphs for water level and TDS are inaccurate The Division has noted similaz discrepancies in previous reports concerning the issue of site locations and problems related to datum values. Responses from CYCC via adequacy responses committed to correcting these problems in future reports. Now these same issues require correction once again. Providing incomplete and invalid data through hydrologic reporting causes unnecessary confusion during the Division's review to ensure the protection of the hydrologic balance as required by Rule 2.05.6(3). In addition to the confusion, it increases the time required to review the report. This operation has a history of lengthy adequacy review of hydrologic monitoring reports. In this particular case it appears that this report lacked any significant quality control prior to submittal to the Division. Based on the three site visits and samples missed and the erroneous reporting noted above, I recommend that we issue an enforcement action to CYCC for failure to conduct hydrologic monitoring in accordance with the approved plan and for reporting inaccurate hydrologic data. CC: Dan Hernandez