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Richartl D. Lamm <br />Governor <br />iii iiniiiiiim iii <br />DEPARTMENT OF NATURAL RESOURCES <br />Davitl H. Ge~ches, Eaeculive Director <br />MINED LAND RECLAMATION DI1 <br />DAVID C. SH ELTON, Director <br />July 15, 1986 <br />Mr. Tommy Raye <br />Raye and Associates <br />976 Welch Court <br />Golden, Colorado 80401 <br />Re: HYDROLOGY MONITORING REDUCTION, TECHNICAL REVISION N0. 02 -- <br />GRASSY GAP MINE, FILE N0. C-81-039 <br />Dear Mr. Raye: <br />The Division has reviewed the above referenced revision request and found it <br />to be complete. Please begin publication of the attached public notice in <br />accordance with Rule 2.07.3(2). Please note that in the future, revision <br />reports will be considered incomplete if they do not include a public notice <br />and a revision application form. <br />Preliminary review has revealed an adequacy issue which must be addressed. By <br />compiling the raw data you have presented, it is evident that the monitoring <br />plan as stipulated in the findings document has not been properly followed. <br />This plan required monthly field parameters and an annual or semi-annual full <br />suite analysis. The data submitted shows several variations from this plan. <br />These are as follows. <br />1. Monthly monitoring data is missing from nearly 75 percent of the data <br />points. A table is attached which depicts the sampling frequency <br />indicated by your data. <br />2. Full suite analyses were performed on each data point sampled. This <br />exceeds the sampling frequency on all sites sampled more than once <br />during the year. <br />3. Sampling was performed at sites which do not seem to be included in the <br />monitoring plan. These sites include: Pond No. 1, Pond No. 5 and 6, <br />clean water ditch, and Grassy Creek. In addition, some of the sample <br />I.D. names are unclear. For example, are "Site 1" and Site "SW-1" the <br />same site? <br />Before the Division can continue its review of the technical revision request, <br />the Rockcastle Company must explain why these discrepancies exist. In <br />particular, the response must address why data points are missing, and how <br />this effects the completeness and representability of the baseline data. <br />423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567 <br />