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REGULATORY PERh'RTS MANAGEMENT, INC. <br />7425 Winter Berry Ln., CastEe Rock. Cglgredo 80108 <br />PhgnB: (303) SSd-7499 FAbX: (303) 66U-3852 <br />April 3, 2008 <br />Mr. Berhan Keffelew <br />1313 Sherman St., Room 2!5 <br />Denver, CO 80203 <br />RE; Blue Grass Grave! Pit M-2008-001, Response to Adequacy Comments <br />Dear Mr. Keffelew: <br />Thank you for your review of our Blue Grass Grave! Pit permit application and providing us <br />comments. We have carefully reviewed your comments and wish to offer the following <br />responses We believe that our response will address your concerns and allow the Division to <br />proceed forward with its review and approval process. <br />Adequacy Items I~ A-F: <br />A) " ..what is the purpose of grave! placement, when water storage is the final land use far <br />the Slte~" <br />Resp~nse.• The purpose of gravel placement is to provide a site for the dispr~sal of reject material <br />that will not interfere with mining operations and not sign f candy affect the functioning of the <br />proposed reservoir. <br />B} "The Qperator did not provide a detailed design for the slurry wall... Please note, the <br />slurry wall design, construction and QA/QC, has to be approved by the Office ofthe State <br />Engineer's Office, with a copy to DRMS. <br />Response: We reviewed the Division's "Guide to Specification Preparation f©r Slurry YYa1ls and <br />Clay Liners as a Component ofA t;olorado Mimed Land Reclamation f ermit", dated September <br />2lIDq, (Guidance Document) and found no requirement that the DRMS may require an Applicant <br />to provide proof that its .slurry wall design, construction and QA/QC must first be approved by <br />the ~ce of the State Engineer in order for the. DRMS t© process this type of application. We da <br />understand that prior to release from reclamation liability, an r~perat4r must demonstrate that <br />the water storage facility meets SEQ leakage requirements. <br />The Cntidance Document only requires that an Appltcant submit "... design documents, plans <br />and specifications, and a quality assurance program as enforceable components of the <br />reclamation permit. " In addition, the guidance document states, "Applicants may use this <br />guidance to their benefit or may provide an application that does not follow the guidance and <br />