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<br />~~~ ~I~~~~~I~~~~~~l~ <br />C c~rpRUs <br />'~`i3 Orchard Valley <br />Cyprus Orchard Valley Mine <br />P.O. Box 1299 <br />Paonia, CO 81428 <br />Phone: 303-527-4135 <br />Fax: 303-527-2234 <br />August 3, 1994 <br />RECEf1/Fp <br />Mr. Kent Gorham <br />FYnriror~ental Prote~-lion specialist AUG o 5 1994 <br />Division of Minerals and Geology <br />1313 ~+a^^?n Street, Room 215 CiC;SiOn of rdir+e~ o.o9Y <br />Denver, Colorado 80203 a15 g (,e <br />RE: PFZtUD.'P 2~A X81-038 • SOBBIDF3i3: I~II7~tII~ <br />Dear Mr. Gorham: <br />Pissuant to as telephone oorrversation of July 20, 1994 i^aaawlina potentially <br />required permit urges under Iarle 2.05.6(6), COVCC is submitting the followinxJ <br />response. COVCC is generally concerned with the nature of sc®e of the d~arges <br />being requested in that no farmal written doa~entation or regulatory <br />justification has been presented to clearly demonstrate c3~angess are required <br />under the provisions of the current regulations. COVOC is reluctant to initiate <br />o3rarges without formal d_rr„~wntati~ fry the Division in those instances where <br />the written regulations are unclear. <br />the subsidence monitoring progz-am and permit text for Orchard Valley relevant to <br />Rule 2.05.6(6) have previously been approved by the Divisioa~. ZYre permit has <br />undergone two renewals, two permit revisions, aryl mmierous tec3uLical and minar• <br />revisions during the interim. ZWo terlurical revisions ('II2-6 and TR-16) <br />specifically addressed rechrctic~s in required subsidence monitoring. 4tbe current <br />?~c,,.r perriirg with regard to Iarle 2.05.6(6) have not previously been identified <br />as ~~~~~ requiring correction. It appea*-~ that certain Division <br />interpretations 1^~~rc7ina the rules and definitions order l3rle 2.05.6(6) have <br />changed. Deficiencies with the permit doc:mient have beo®e evident to the <br />Division in light of the au7ent regulations and interpretations governing this <br />area. In the absence of specific, clear, aryl caincise language within the written <br />regulations to refer to, it is problematic to respotd to arri difficult to justify <br />the requested rl~arrges within the pP*-m; t without having underlying and supportive <br />docamwntation frau the Division explaining the specific essence of and need for <br />the requested cYrarges. OOVCC is anxious and will work diligently to alleviate <br />any Division concerns whidr are tenable tiuider the CUrZ~ellt regulations. However, <br />with respect to other changes as indicated in my letter of July 14, OOVOC <br />mainta, n-a that the existing ~*~++; t language aryl monitorirr3 ps«~am are consistent <br />with and sufficiernt to meet the ~iiroTiw..rc of the regulations. <br />With regard to sc~oe of the specific elements of as ocarversatian, QOVOC first <br />cror~as with the Division's position that a revised projection of the potentially <br />suksidence affected area at Orchard Valley is warranted in light of nLn++Amic mine <br />plan cY~anges which have occurred since the initial projection was made. Zt>e <br />initial projection is presented in Volume 3, Slrbsidence Study, Geo-Hych-o <br />Consulting, Inc., Plate 14. OOVOC will p*_-P_pa*p and sutmit a revised projection <br />