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SENT ~Y~Administretion Office 110-19-93 111~47AM CYPRUS YAMPA VALLEY <br />~ ~CY~~~S <br />303 832 9106111 2 <br />Cyprus Yampa Valley Coal Corporation <br />saee7 ~uK co~~a liosd ~~~ <br />Oak Creak Colorado 80487 <br />808-876-3800 <br />October 19, 1993 <br />Kent Gorham <br />Reclamation Specialist <br />Division of Minerals and Geology <br />1313 She-man Street, Room 216 <br />Denver, CO 80203 <br />Ra: <br />Dear Mr. Gorham; <br />The following information is being provided for Inclusion into the penalty assessment process <br />for the referenced Notice of Violation. Please forward a copy of this information to the <br />Asaaesment Officer reviewing this NOV. <br />DMG Issue <br />1) Baseline date for lines A-A' and B-B' was not collected one month prior to the <br />commencement of longwell mining ea required by your approved permit, and Rule <br />2.06.616)(c)(D) <br />The Senior Engineer in charge of subsidence monitoring, Mr, Collin Stewart, interpreted the <br />referenced items to moan "within 30 days', rather than "30 days prior" as the Division has, <br />resulting in the current issue. <br />According to Mr. Stewart, one should ideally complete baseline surveys as close ea possible <br />to the start of active subsidence, thus providing a minimal opportunity for other surface <br />activltlea to impact the subsidence baseline. According to Mr. Stewart, the key technical <br />requirement for baseline data are the monument elevations prior to the start of subsidence, <br />and the baseline monitoring which was conducted at the Foidsl Creek Mine satisfies this <br />technical requirement. <br />DMG Issue <br />2) One week of date collection was not done between 12/22/92 and 1/7/93 (16 days) <br />