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PHASE I <br /> <br />Backfilling and Grading <br /> <br />During the period from 2003 to 2015, the methane drainage wells were sealed and abandoned and <br />associated access roads within the SL-01 bond release areas were re-graded and restored to the <br />approximate original contours. It was during this time that BRL backfilled and sealed the Freeman <br />Gulch Vent Shaft and the Hubbard Creek Vent Shaft. The vent shaft sites were graded and restored <br />to the approximate original contours. In addition to the drill holes and shaft sites, the reclaimed <br />disturbances associated with the subsidence mitigation project of the Pitkin Mesa Pipeline were <br />graded and restored to the approximate original contour. The Phase I areas subject to this SL-01 <br />bond release consist of: 63.7 acre of backfilled and graded drill hole pads; 12.33 acres of backfilled <br />and graded drill hole access roads; 2.9 acres of backfilled and graded vent shaft sites; and 4.0 acres <br />of backfilled and graded Pitkin Mesa pipeline disturbance. Based on the on-the-ground bond <br />release inspection of the bond release areas and a review of the approved reclamation contour map <br />compared to the pre-mining contours of the area, the areas pertaining to the Phase I release of SL-01 <br />have been graded to the approximate original contours of the pre-mining conditions. <br /> <br />Drainage Establishment <br /> <br />The drill hole disturbance areas, associated roads, vent shaft pads, and Pitkin Mesa Pipeline <br />disturbances have been graded in accordance with the approved post-mining topography. There are <br />no significant drainage channels associated with the 82.93 Phase I acres. All SL-01 acres are <br />identified as small area exemptions (SAE) and do not report to a sediment pond. The sediment <br />control for the associated SAEs consists of erosion control wattles, silt fence, and vegetative cover. <br />The run-off of the area is in the form of sheet flow due to the slope of the pads. The areas displayed <br />excellent vegetation growth with no evidence of instability or erosion. <br /> <br />Summary and Conclusions <br /> <br />Based upon a review of the mine permit, the applicant's bond release application, and site <br />inspections, the Division finds that for the 82.93 acres subject to a Phase I bond release under SL-1, <br />Bowie Resources, LLC has completed backfilling, grading and drainage reestablishment in <br />accordance with the approved reclamation plan. <br /> <br />PHASE II <br /> <br />Topsoil Redistribution <br /> <br />A designated permit topsoil depth is not required (C-1996-083, Volume 1, Section 2.05.3(5)) for <br />soil replaced on the Bowie No. 2 Mine. All suitable A and B horizons are required to be salvaged. <br />Soil replacement has been conducted and reported annually over the course of the mine life, and <br />verification sampling has been periodically conducted by the Division. <br /> <br />Per Rule 4.06.2(2), a variance from topsoil removal for ‘good cause shown’ is allowed. A variance <br />from topsoil removal is approved in areas where slopes exceed 2H:1V, where the soil is too thin