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III IIIIIIIIIIIIIIII 999 Proposed Strategy for Conducting the Waste-Banks Special Focus Study for the Colorado FY1997 Oversight Review General Comments The OSM ad hoc technical team members ([he Tech Team), consisting of Glen Golden and Ron Sassaman, would like to meet with the appropriate DMG staff members to plan the special focus review for the Waste Banks topic. The following comments, questions, and proposals have been prepared as tentative items that may be discussed with DMG to plan the review. The Tech Team would like to consider the review of this topic as an evaluation of suitability, no[ an intensive determination of compliance. Therefore, the Tech Team doesn't plan to conduct formal inspections during site evaluations. In the spirit of State primacy, we believe that DMG should take the lead in conducting inspections, should the need azise; however, OSM will be available to assist DMG with inspections, if requested. The "Attachment to the Ovetsight Agreement" (the Agreement), dated 12/18/96, identifies three main evaluation categories; ie.: 1) operator inspections, 2) construction and maintenance of water control structures, and 3) waste pile construction requirements. From this information, the Tech Team concludes that the review is based on the idea that reclamation success can be anticipated provided waste banks aze constructed as designed. Furthermore, we understand that the main purpose of the field reviews will be to determine if there are any obvious deviations from the permit waste-bank designs at the time of the site visits. The Tech Team will proceed under this assumption and report findings accordingly, unless otherwise advised by DMG. The Tech Team recommends that a review strategy be developed to identify the scope of review, evaluation method, respective duties of the team members, and schedule for the site visits. The answers to the attached questions will provide the basis for planning the reviews. (We recommend that DMG take the lead in providing initial answers to the attached questions.) The Tech Team would volunteer to prepare a draft format for the special focus reviews, and then present the draft to DMG for consideration. Because the procedures developed will be informal and unofficial, no management approvals are anticipated--the procedures would be intended only to clarify responsibilities and expectations. When convenient, we would like to meet with the appropriate DMG staff members to discuss this proposal. If there are any questions regarding this proposal, including the attachments, please contact either Ron Sassaman (844-1521, a-mail: RSassama@OSMRE.gov) or Glen Golden (844-1458, e- mail: GGolden@OSMRE.gov). The OSM Tech Team can receive fax correspondence at 844-1545. We'll be waiting to hear from you..