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iiiiiiiiiiiiiiiiiii 099 DATE: November 9, 1999 TO: Dan Hernandez J~ FROM: Dan Mathews (~I -I`I ~/ly RE: Roadside Mine NOV Assess ent Request Permit C-81-041, NOV CV-99-013 Dan, I need to request a proposed penalty assessment for the referenced NOV. The NOV was issued Ocl 18, so next Wednesday, November 17, is the 30'" day. I have enclosed the NOV and relevant page from the AHR review letter which was the basis for the NOV. Much of the missing data cited in the NOV was provided N the operator's response on November 2 (enclosed). Essentially, missing data was limited to data from a continuous recorder at the downstream flume site on Rapid Creek (SWGS-01). Data was missing for three weeks in August, 1997, and again from December, 1997 though the end of August, 1998. The long period of time during which the SWGS-01 recorder remained inoperative h 1998 is likely related to environmental coordinator, Larry Reschke's sudden departure in April, 1998. Before Jim Stover was hired a couple months ago, two different environmental coordinators had been employed by the operator subsequent to Reschke's departure, and this probably contributed to the extent of data missing from the reports. Jim Stover was more successfid in locating the missing data than John Walters, his immediate predecessor, had been. As to the seriousness of the data gaps-1 discussed the hydrologic mmifica[ions with Jim Burnell. Given the long record of data we have on the streams in question (over 15 years, with no indication of mining impact), the nature of the stream flows (largely controlled by releases from water supply reservoirs on the headwaters), and the Cact that mining has been suspended since 1996 within the Rapid Creek and Cottonwood Creek watersheds; i[ would appear that potential environmental consequences of the monitoring gaps are relatively minor. One previous NOV was issued [o the operator in the past 12 months (NOV CV-99-007), issued August 20, 1999. Operator has signed a settlement agreement for that NOV. As oC today, Abatement Steps 1 and 2 have been complied with 1999 water year data for S WGS-0l has not yet been submitted, so Abatement step 3 has not been satisfied, and consequently the NOV has not yet been terminated.