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~_ <br />~II ~II~I~~I~~~~~ ~I~ <br />sss <br />STATE OF COLORADO <br />DIVISION OE MINERALS AND GEOLOGY <br />Deparlmenl of Natural Resources <br />1311 Sherman St., Room 21 5 <br />Denver, Colorado 80207 <br />Phone: (3071 866-1567 <br />FA%:13031 032-8106 <br />DATE: July 19, 1994 <br />TO: Berhan Keffelew <br />FROM: Jim Pendleton <br />I~~~~ <br />DEPARTMENT OI <br />NATURAI <br />RESOURCE` <br />Roy Romer <br />Governor <br />lames S. Lochhead <br />Executive Director <br />Michael B. Long <br />Dwision Dnecmr <br />RE: CRESSO NII - "Response to 'Problem Noted' Contained In <br />Inspection Report from OMLR Dated July 14, 1994 - <br />'QA/QC Oversight"' (Permit No: M-80-244) <br />In response to your request, I have reviewed the response to the <br />"QA/QC Oversight" problem noted in my inspection report of July 14, <br />1994. Briefly, I had noted a concern regarding the degree of <br />oversight coverage occurring at the site. My concern arose from <br />the installation of some potentially substandard material in a <br />secondary underdrain. As Mr. Hardaway states, I was informed that <br />the material in question had already been declared substandard and <br />was to be removed and replaced. It was for this reason that I did <br />not consider the more harsh alternative of issuing a Reason to <br />Believe Letter to CC&VG. <br />My concern arose because the primary site inspector was not in <br />evidence during the specific half hour instance cited. Terry did <br />arrive as we were exiting the site and was briefed by Dave Kidd. <br />I believe the principal inspector has been doing a laudable job. <br />However, I am concerned that he may be stretched a little thin in <br />attempting to cover the entire site activity. I suspect that <br />additional manpower may be necessary, particularly once the <br />underdrain and underdrain pipeline installation is completed. <br />Because the purpose of CQA Oversight is to avoid the undesirable <br />consequence of a construction failure, we must judge its apparent <br />level of application indirectly. CC&VG has provided a list of the <br />"critical components" of the Phase 1 Leach Facility construction, <br />as I requested. It appears to be complete. They have also <br />provided a "DRAFT" table specifying "Approximate Frequency of On- <br />Site Visual Inspection". CC&VG proposes 100a visual inspection <br />coverage for practically all critical components, with the <br />exception of "Drain Rock" and "Geotextile Installation". <br />Coincidentally, my specific concern related to a "Drain Rock" <br />installation instance. <br />