Laserfiche WebLink
<br />Mr. Steve Renner 3 <br />document where ten years is referenced is under the recommendation, "* * * For <br />the Roadside pile, I would recommend that we conditionally approve the 6 inch <br />cover depth, with the provision that the currently revegetated portions of the pile <br />meet cover and production success criteria during the 9th and 10th years of the <br />bond liability period." (emphasis added) The bond liability period is significantly <br />different than a field trial test period. As such, the current approved permit only <br />allows for afive-year trial period that would have expired in 1988, and at this point <br />DMG has yet to approve cover of less than four feet. <br />After additional review, AFO has found that failure to properly certify the refuse <br />piles during critical times of construction should have been addressed outside of <br />the contemporaneous reclamation TDN. When a Federal reinspection occurs, and <br />if this violation still exists, appropriate action will be taken. <br />DMG has replied twice to violation 2 of 2. The first was formally found to be an <br />inappropriate response and DMG chose to issue an NOV rather than request an <br />informal review by the Deputy Director. The NOV issued by DMG does not cause <br />the violation to be corrected within the requirements of the Colorado program and <br />the five-day time period for requesting an informal review after DMG received a <br />written inappropriate finding has since passed. A Federal inspection of the <br />Roadside/Cameo Mine is immediately required because DMG did not appeal that <br />finding of an inappropriate response within allowable time limits and subsequent <br />action by DMG did not change the initial finding of an inappropriate response. <br />After telefaxing a copy of this letter to DMG, AFO will telephone to notify your <br />office when the Federal inspection will occur. A DMG representative may <br />accompany AFO on the inspection and take the appropriate enforcement action. <br />Sincerely, <br />~.~-~~~~ <br />a-LT~- r-n-~, <br />Robert Hagen, Director <br />Albuquerque Field Office <br />