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<br />~~I ~I~~I~II~I~~~~I~ <br />C c~~tus <br />~ 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 />November 24, 1993 <br />P,ECEI\/ED <br />Mr. David Berry <br />Lead Reclamation Specialist IVOV 2 9 1993 <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver, OD 80203 nh; i~~~^r!~.,:~~;~~~:: 1..: ..rW <br />RE: PER4R'1' NO. G~81-038; NW C-93-147; 1992 RS~OLWR bgHiITQt'It~ <br />Dear Mr. Berry: <br />Ln response to Mr. Steve Shuey's letter of Nov. 10, 1993 regarding NOV C-93- <br />147, COVCC is submitting the following information for consideration in <br />assessing the civil penalty associated with this violation. I am aware that <br />Mr. Shuey is on vacation so I'm forwarding this response to you for further <br />handling. I apologize for the length of this response but know of no other <br />way to illustrate the questionable and buniensome nature of the majority of <br />the monitoring rern~iremerlts currently i-il the permit. COVCC aclmarledges its <br />failure to totally adhere to the hydrologic monitoring program contained in <br />the permit during 1992 but respectfully requests the Division to consider the <br />following points in evaluating the seriousness of this violation and the <br />associated civil penalty. Ln short, the extensive hydrologic monitoring <br />requirenents in effect during 1992 overwhelmed the resources available to <br />COVCC to adhere to the program. As the irdividual responsible for harx3ling <br />the hydrology monitoring program, I failed to address revision of the program <br />in a timely fashion. As a result, data collection requirements were not met. <br />OOVCC asks the Division to wnsider that Orctla~.-d Valley must operate with <br />extremely limited resources in a hic~lly cong~etitive market which demands <br />elimination of all expenses and efforts not absolutely nay. ~VCC <br />believes the majority of the hydrologic monitoring ocamnitments currently <br />rewired by the permit can and should be el~m~*uted or revised to enable NVCC <br />to focus on those areas which are of more critical ooncel-n to the Orchard <br />Valley mine. COVCC aclvwwledges its oversight in failing to address <br />modification of the hydrologic monitoring program at an earlier date, but is <br />confident that ample justification exists for modifying the program <br />extensively to eliminate the majority of the monitoring currently required and <br />thereby free resources to focus on that monitoring which is beneficial to all <br />concerned. <br />Gt7VGC asks the Division to consider the necessity of continued monthly <br />monitoring at various sites given that extensive baseline data has been <br />