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day time period from the completeness date. The bond release inspection was scheduled and <br />conducted on June 4', 2013. The site inspection was conducted in accordance with Rule 3.03.2(2). <br />Jared Ebert with the Division, Christine Belka and Alan Boehms with OSM, Jennifer Maiolo with <br />the Bureau of Land Management, Roy Karo and Jay James of Seneca Coal Company attended the <br />inspection. None of the other land owners of record attended the inspection; however, all land <br />owners were notified of the inspection via certified mail. A summary of the bond release inspection <br />and any concerns identified are presented in Section III, below, and detailed observations of the <br />inspection are documented in the June 4, 2013 inspection report that was issued June 14, 2013. <br />On June 18, 2013 the Division sent an adequacy review letter to SCC in regards to the SL -4 bond <br />release application that identified three items that needed to be addressed. First, the SL -4 bond <br />release area encompassed the following impoundments: sediment ponds 005, 006, 009, 015, 016 <br />and 017; stock ponds T -2, 3, 5, 18, 20, 22, 24, 26 and 27. SCC had previously submitted TR77 <br />to revise the permit to leave these impoundments permanently in accordance with Rule <br />4.05.9(13). However, not all of the required documentation to leave these impoundments as <br />permanent features was submitted with TR77, and SCC committed to supplying this <br />documentation prior to requesting bond release of these impoundments. The Division required <br />SCC to submit the remaining information /documentation to leave these structures as permanent <br />impoundments. Second, it was noted that not all of the required remediation activities of the Pit <br />Ramp Slide Area had been conducted in accordance with the approved plan in Attachment 20 -E <br />of Tab 20 of the permit. Third, during the bond release inspection it was noted that a gully had <br />formed in the PM 4 -D drainage and the Division required the operator to repair this gully prior to <br />approval of Phase I bond release. <br />SCC responded to the Division's adequacy review in a letter dated July 15, 2013. The letter <br />indicated they were waiting on the State Engineers Office (SEO) for documentation necessary to <br />leave the above noted impoundments as permanent features. In regards to the Pit Ramp Slide <br />Area, SCC submitted a letter from Northwest Colorado Consultants, Inc. (NWCC) with <br />reasoning for not completing the remaining remediation activities required in the permit. SCC <br />submitted a minor revision (MR75) to update the remediation plan in the permit based on the <br />NWCC findings. The Division engineering staff reviewed MR75 and this revision was approved <br />on August 7, 2013. In regards to the PM 4 -D drainage, SCC indicated they had not been able to <br />repair the gully and requested this drainage be removed from the bond release area. <br />On July 29, 2013 the Division sent a second adequacy review letter to SCC in regards to the SL- <br />4 Bond Release application. This letter indicated the permanent impoundment items remained <br />outstanding and would need to be addressed prior to the approval of Phase I bond release for <br />these areas. Also, the Division indicated they concurred with the updated remediation plan for <br />the Pit Ramp Slide Area and that SCC would need to update the remediation plan in the permit. <br />SCC revised the permit as indicated above through MR75. The PM 4 -D drainage was removed <br />from consideration from bond release. <br />SCC responded to the Division's second adequacy review with a letter dated August 1, 2013. <br />Again, SCC indicated they were waiting on SEO documentation to finalize the permanent <br />impoundment demonstrations. All other adequacy items were resolved to the Division's <br />Page 8 of 18 <br />