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SENT BY~Xerox Telecopier 7021 ;. 8- 8-s4 ; 3~23PM ; <br />Honorable Roy Romer <br />September S, 1994 <br />Page 2 <br />303A323304y 303 A32 8106:# 3 <br />D~a~~ <br />their opinion that Kea's approved permit does not meet the AOC standard for Pit 1 until <br />the bond release inspection on May 12, 1994, despite several occasions when they copld <br />have done so. In addition, the DMG notified the AFO that Ken: was perforating the d~ork <br />in monthly inspection reports starting in May 1993, <br />1. OSM did not notify the DMG and Kerr of concerns that the 1990 <br />revision to II{err's baclddling and grading plan violated the AOC ' <br />standard. <br />The Summary states that OSM's AFO expressed concern to Kea and the DMC`r <br />about the amount of overburden available w complete backfilling and grading in all a#eas <br />of the Mine, based on as inspection by Steve Rathbun and Henry Austin in April, 1993, <br />While we do not know what the OSM and DMG inspectors may have discussed in <br />general terms, the critical point is that the OSM inspectors did not indicate the revised <br />bacl~illittg and grading plan for Pit 1, which had been approved by dte DMG is 1990; <br />failed to comply with the State's AOC standard. <br />The standard procedure is for the OSM sad DMG inspectors to hold a closeout; <br />meeting after. an inspection, where they agree on a list of permit waceras and other ' <br />matters to be addressed The respective OSM and DMG inspection reports then include <br />all such items. <br />m~~ <br />