2008-03-04_APPLICATION CORRESPONDENCE - C2006085

• Permit No: C2006085
• IBM Index Class Name: Application Correspondence
• Doc Date: 3/4/2008
• Doc Name: Proposed Decision and Findings of Compliance
• From: DRMS
• To: Northfield Partners, LLC
• Media Type: D
• Archive: No

On November 27, 2006, the Division published notice of a public hearing/informal
conference to be held in Florence, Colorado on December 12, 2006. The notice was
published at least two weeks prior to the hearing as required by Rule 2.07.3(6)(b)(ii).
The hearing was held on December 12, 2006 within 60 days of the last publication of
the filing of the application as required by Rule 2.07.3(6)(b). An audio tape recording
was made of the hearing as required by Rule 2.07.3(6)(b)(iv). Objectors were informed
that the Division's initial adequacy review had recently been completed and requested
additional information regarding the topics identified by the objectors.
The Division forwarded our initial adequacy review to EAI on November 28, 2006. This
initial adequacy review included review for adequacy in addressing all required portions
of the Rules, excluding Rule 3, Performance Bond Requirements. On December 15,
2006, the Division forwarded adequacy review comments addressing the requirements
of Rule 3.
The Division received EAI's responses to the November 28 and December 15
adequacy review letters on May 10, 2007. Additional information and materials were
received on May 18 and May 30, 2007.
After review of the revised materials, on June 18, 2007, the Division sent a second
adequacy letter detailing any issues that remained outstanding and indicating resolution
of other issues as appropriate. The Division also provided a detailed written estimate of
the reclamation costs as required by Rule 3.02.2(1), included as an attachment to the
second adequacy letter.
On August 23, 2007, EAI submitted a third round of additional permit text and materials
to resolve remaining issues. Following the Division review of these materials a third
adequacy letter was forwarded to EAI on October 19, 2007, narrowing the list of
remaining issues requiring resolution.
The Division received responses to our third adequacy letter on November 6, 2007.
Based on review of this fourth submittal of revised and additional materials, the Division
determined that all outstanding issues were resolved or could be resolved through the
permit stipulation process.
The Division queried the Applicant Violator System (AVS) again on March 3, 2008, the
day of the proposed decision. The AVS recommendation and OSM evaluation resulted
in "no violations". The Division recommendation for this AVS check coincident with the
proposed decision was "Issue".