2011-09-09_REVISION - M1981185 ‎(43)‎

• Permit No: M1981185
• IBM Index Class Name: REVISION
• Doc Date: 9/9/2011
• Doc Name: Response to Fifth Adequacy Letter
• From: R Squared, Inc.
• To: DRMS
• Type & Sequence: CN1
• Media Type: D
• Archive: No

Mr. Wallace H. Erickson
Response to Fifth Adequacy
September 9, 2011
Page 25
a. The work plan proposed in Attachment D -1 was reviewed by staff
member Peter Hays. Mr. Hays has generated a technical review
memorandum in which he identifies outstanding adequacy issues for
Attachment D -1. Copy of Mr. Hays' technical review memorandum,
dated August 22, 2011, is attached. Please address the adequacy issues
identified by Mr. Hays.
b. The work plans proposed in Attachments D -2, D -3, D -4 and D -6, have
been reviewed by staff member Tim Cazier. Mr. Cazier has generated a
technical review memorandum in which he identifies outstanding
adequacy issues. Copy of Mr. Cazier's technical review memorandum,
dated August 22, 2011, is attached. Please address the adequacy issues
identified by Mr. Cazier.
c. The work plans proposed in Attachments D -5, D -6, D -7, and D -8, have
been reviewed by staff member David Bird. Mr. Bird has generated a
technical review memorandum in which he identifies outstanding
adequacy issues. Copy of Mr. Bird's technical review memorandum,
dated August 23, 2011, is attached. Please address the adequacy issues
identified by Mr. Bird.
d. Several of the work plans discuss the need for future investigations and
the gathering of additional information before finalizing a specific plan.
Such plans are conceptual in nature and fail to provide the information
required by the Act and Rules. However, given the Cease and Desist
Orders associated with the unresolved violations, the Applicant is
somewhat limited to conceptual plans where additional geotechnical
and/or geochemical information are required. Therefore, the Division
could accept conceptual work plans if the plans include a thorough
description of the process for information collection, analysis, submittal
for Division approval and, implementation upon receiving Division
approval, and a commitment to submit the newly collected information,
updated analysis and resulting finalized designs to the Division through
either the Technical Revision or Amendment process. The conceptual
work plans provided in the application did not commit to follow -up
Technical Revisions or Amendments. The absence of such commitment,
specifically stated within each of the individual work plans, is grounds for
denial of the conceptual work plan.
DEN 97,599,531v1 9 -9 -11
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