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IA'1 ~)1 l,I ll r)ir AlUl II II Il null IL I nM' N"nun <br />UCP AfII MENT OP NAfI)tIAL PCSOUHG.$ <br />U Munk P.lSCOB, L,ccubvC nvcunr <br />,~~i~i;U 1,/1RU ti1~(:1~/1A1/1"1'lt1N <br />423 Centennial Builtlln'~, 1313 SFlerman Street <br />Denver. Colorado 60203 7e1. !3031 839-3567 <br />November 14, 1980 <br />Mr. Andrew P. Schissler <br />Empire Energy Corporation <br />P.. O. Box 68 <br />Craig, Colorado 81625 <br />David C. Shelton <br />Director <br />Re: Submission'Requirements for .Final Permit Application <br />Dear Andy: <br />As agreed in our meeting ol. November 3, 1980, I am enclosing one copy of <br />the Initial Completeness Review of the Eagle Mine Complex of Febraary, 1980 <br />by the OSM and one copy of the Division's letter of June, 1980 summarizing <br />the portions of Empire's permit application considered to adequately <br />address the State's Final P.egulatory Program, as the program was <br />interpreted at that time. Delow, Z have also attempted to compare <br />these documents and st,rnmarize the status of Empire's application with' <br />respect to the State's Final Regulatory Program. <br />With regard to the summary, several points need clarification. First, <br />the OSM initial completeness review applies only to the permit application <br />submitted on October, 1979; there has not been any review by the O~M of ' <br />materials submitted by Empire as "Volume D" in February, 1980. Second, <br />the Division's letter applies to all material submitted by Empire as <br />'part of the permit application, Volumes 1-4 of October, 1979 and Volume O <br />of February, 1980; however, some material was only reviewed with respect <br />to the interim regulations. 7'1)crefore, some of the issues in OS79's <br />review have already been addressed by the February, 1980 submisc:ion and <br />some items reviewed by the Division under the interim standards may <br />address the final program standards in whole or in part. Finally, both <br />the State and Federal permanent regulations have evolved since the <br />spring of 1980 as a result of litigation and attempts by the Division <br />to "tailor" Colorado's Regulations to the environmental condition cf <br />the State. <br />Below I have briefly arldresr;ed each section of the permit appl:'-ation on <br />File with the Division Chrou'Ih the 1ebruary, .1980 submission. 'Phe <br />"finding" yenera.ily rcl•lecl~ Lhe concLr.;ions found in the appropriate <br />review document.. !lnwever, in some cases where regulatory standards have <br />been revised or where an int:erptetation concerning regulatory standards <br />has changed since June, 1980, the finding under rile "State" column may <br />(cont'd) <br />