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• <br /> <br />STATE OF ~ III IIIIIIIIIIIIIIII <br />999 <br />COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmem a Natural Resour ces <br />1313 Sherman 51 , Koom ?15 J <br /> <br />Denver, Colorario 80?03 II <br />~~ <br /> <br />Phone: (3031 R66 3567 I <br />FAY: 13031 R3'-H106 <br /> DEPARTMENT OF <br /> NATURAL <br /> RESOURCES <br /> ROy Romer <br /> Governor <br />DATE: Februa 28 1996 <br />~' lanes s. Ln~hhead <br />E <br />D <br /> , eecunve <br />ueaw <br /> Michael8 Long <br />TO: CC & VG File No. M-80-244, Carlton Project Division o~renm <br />FROM: Bruce Humphries <br />RE: Meeting with Company on Proposed Revision to Permit, <br /> February 7, 1996 <br />On February 7, 1996, representatives of the Carlton Project met with Division staff to <br />voice their concern over our proposal to require certain changes to the permit to be <br />permit amendments. Present at the meeting for the Division were Mike Long, <br />Bruce Humphries, Jim Pendleton, and Jim Stevens. Present for the company were <br />Jim Komadina, Bob Micsak, and John Hardaway. <br />Based on a review of the proposed changes, as submitted, the Division's engineering <br />staff recommended that certain specification changes be process as technical revisions. <br />Changes to the low volume collection systems (LEGS) and drain cover layer should be <br />handled as permit amendments. The reasoning was that these two changes could <br />potentially affect the designed functioning of the facility. <br />The operator argued that the changes to the LLCS and drain cover would not affect the <br />functioning of the facility. In addition, the amendment process would cause operational <br />difficulties in getting the phase two facility constructed this construction season. <br />Mr. Hardaway stated that the change did not fit the definition of an amendment as <br />outlined in the Act and Rules. Also, the change was not in his estimation a change to <br />the environmental protection plan. <br />Jim Pendleton explained to the company representatives why the Division did not agree <br />with his assessment and listed the reasons. <br />We discussed various review processes that included allowing the company to submit <br />the changes as a Technical Revision, but noticing as if it were an amendment. The <br />reason for the notification being the Division's concern that all parties mentioned in the <br />project be aware of any revision to the permit. <br />