2014-12-19_REVISION - C1980005 (2)

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L PROCEDURES AND SUMMARY OF THE REVIEW PROCESS Reclamation History of Bond Release Area The total permit area at the Seneca II Mine is 386.50 acres. The total disturbed acreage is 271.20 acres. The Division has processed five previous bond release applications for this mine site. In 2010, Permit Revision No. 2 (PR -2) was approved to reduce the size of the original permit area of the Seneca II Mine to accommodate the Peabody Sage Creek Mine (C- 2009 -087). PR -2 reduced the size of the permit from approximately 3,011.9 acres to the currently permitted 386.50 acres. Bond release application SL -01 was submitted May 24, 2006 and found complete on July 18, 2006. At the time of the SL -01 submittal, Seneca Il Mine consisted of 1,968.8 acres of interim and permanent program disturbed acres and 326.5 pre -law disturbed acres for a total of 2295.3 disturbed acres. Bond release SL -01 requested Phase I bond release on 2,054.5 disturbed acres, which were composed of 259.1 acres of pre -law lands and 1,795.4 acres of interim and permanent program lands. The Division approved the Phase I bond release on December 27, 2006. Bond release application SL -02 was submitted June 27, 2007 and found complete on August 15, 2007. Bond release SL -02 requested Phase IVIII bond release on 259.1 reclaimed acres of pre -law lands within the permit area. SL -02 was approved on November 29, 2007 for 257.71 acres. It was determined that Bond 9264191 issued by the National Fire Insurance Company of Hartford for Permit No. 75.54 C /A, in the amount of $1,355,000.00, was dedicated solely to the pre -law lands. Based on reclamation cost assessments performed in association with SL -01 and SL -02, the Division determined that reclamation liability associated with pre -law lands (68.79 acres) that were not the subject of SL -02 was $285,484.00. Thus, the Division approved SL -02 in the amount of $1,069,516.00 from Bond No. 9264191. SCC submitted an application for a Phase II bond release, SL -03, that was received by the Division on May 19, 2008 and found complete on June 18, 2008. SCC initially requested Phase H release on 1,793.5 acres of permanent program land. The reclaimed lands were divided into separate bond release blocks (BRB). Each BRB included multiple reclamation parcels. Within a particular reclaimed block, parcels were reclaimed with relatively consistent techniques and seed mixes. Permanent program lands included 902 acres in BRB -3, 577.7 acres in BRB -4, and 2.7 acres in BRB -5. No pre -law lands were included in SL -3. The SL -3 bond release request was limited to those portions of the permanent program lands that were previously granted Phase I release under SL -01. During the review process, SCC withdrew the 577.7 -acre BRB -4 and the 2.7 -acre portion of BRB -5 from the SL -03 application. On April 1, 2009, the Division approved Phase II reclamation liability release on 1213.1 acres (311.1 acres of interim program land in BRB -2 and 902 acres of permanent program land in BRB -3). The Division approved a liability release of $1,975,695.00 with the approval of SL -3. SCC submitted an application, SL -04, for a Phase I bond release on October 15, 2008. This application was found complete on December 1, 2008. The application requested Phase I release on 135.3 reclaimed acres of permanent program lands. The area requested for release included a 125.8 - acre block of reclamation in the southeast portion of the permit area, an 8 -acre portion of the reclaimed solid waste disposal site, and a 1.5 -acre corridor associated with a postmining drainage channel. These acres were originally associated with SL -1, but not approved at that time. SL -4 was