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C -1981 -008 TR -62 28- Mar -2012 <br />Ross Gubka — Adequacy Review Page 2 of 2 <br />The Division received no objections to TR -62. On March 5, 2012, the OSM submitted a <br />Technical Review and Technical Review Finding letter to the Division. The OSM found that the <br />plans and procedures outlined in the TR -62 application were, in their view, in accord with <br />Colorado Regulations 2.04.9 and 2.06.6. On March 6, 2012, a fax was received from Turner - <br />Morgan. The fax stated that it was "not an objection to TR -62 ", but included concerns regarding <br />other elements. The Division responded in a letter dated March 12, 2012, acknowledging receipt <br />of their comments. Copies of the OSM review, the Turner - Morgan fax, and the Division's <br />response are attached to this letter, for your records. <br />Adequacy Comments <br />The Division has only three adequacy comments for the TR -62 application. These do not relate <br />to the subject matter of the items already submitted; rather, they address the insertion of these <br />materials into the permit. <br />1. In the Table of Contents for Section 2.04.9, please add, "Map 2.04.9 -4 — 2011 Soil <br />Sampling Piles — Morgan Property" to the List of Maps. <br />2. With TR -61, subheading 18 was added to page 2.04.9 -43 of the permit text. For TR -62, <br />please revise the last sentence to read, "The Sampling and Analysis Plan (SAP) prepared <br />by Key -Ag under TR -61 can be found in Attachment 2.04.9 -10." <br />3. Please add a new paragraph to subheading 18 on page 2.04.9 -43 which addresses the new <br />information provided with TR -62. Suggested wording for this paragraph is as follows: <br />"Sampling occurred in November and December 2011. Field modifications made to the <br />plan are described in a February 14, 2012 Technical Memorandum from Key -Ag, and in <br />the Office of Surface Mining's Mine Site Evaluation dated January 18, 2012. These two <br />documents, including Map 2.04.9 -4 which identifies the various piles that were sampled, <br />have been added to Appendix 2.04.9 -10 with TR -62." <br />This concludes the Division's adequacy review for Technical Revision No. 62. Please do not <br />hesitate to contact me with any questions you may have. <br />Sincerely, <br />Marcia L. Talvitie, P.E. <br />Environmental Protection Specialist <br />Attachments (3) <br />cc: Ben Langenfeld, Greg Lewicki & Associates <br />David Berry and Sandy Brown, DRMS (w /o attachments) <br />