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<br />.~ <br /> <br /> <br />indication or discussion which led the Division to believe <br />that the extension of time to conduct bedrock monitoring was <br />for permit ,~C-84-062. If extensions were contemplated for <br />hydrologic monitoring for #C-84-062, they were not discussed <br />in the field nor was a follow-up correspondence received. The <br />Divisions policy is to grant extension of time for reasonable <br />and specific requests on an occasional basis when there is a <br />valid need or set of extenuating circumstances. Clearly, <br />situations like this one are reason to re-evaluate the way <br />these requests are handled in the future. <br />Conclusions <br />The Division stands by the previous comments with regard to CYCC <br />conclusions. Furthermore, we think you will agree that if the <br />Division is required to challenge every statement made by an <br />operator unless it is known to be absolute fact, the permitting <br />process and subsequent mining operations would quickly grind to a <br />halt. We simply stated previously that we do not agree with a <br />statement made by CYCC, regardless of how many times this statement <br />was made in the past. Because the statement was not questioned <br />previously does not make it fact nor indicate incomplete review. <br />Remember, CYCC is the party required to make conclusions and the <br />Divisions' responsibility is to review those conclusions. No <br />reasons were given by CYCC as to why a drop in manganese would be <br />indicative of a return to pre-mining geochemical conditions. The <br />Division is unaware of manganese concentrations being used <br />individually as an indicator of general geochemical conditions. <br />Has sulfate returned to baseline conditions? What about TDS? For <br />the record, the Division believes the water quality in well 008-SP- <br />5A is far from representative of baseline conditions and is <br />confident that the data collected by CYCC supports that position. <br />If you have additional concerns with regard to this issue we can <br />discuss them at your convenience. <br />Please respond to the above issues within 30 days of receipt of <br />this letter. <br />If you have questions, please call me. <br />Sincerely,,,a~~ -.~ <br />Kent A. Gorham <br />Environmental Protection Specialist <br />