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Keenesburg Strip Mine (C-1981-028) MT-07 <br /> <br /> <br />Page 6 <br /> <br /> <br /> <br />Section V - Enforcement Actions <br /> <br />No violations have been issued to this mine operator since 1994. <br /> <br />Section VI - Identified Issues and Required Revisions <br /> <br />Pursuant to 2.08.3, the Division finds that the permit application C-1981-028 contains possible <br />deficiencies following the review for the purposes of fulfilling the requirements of the Act and the <br />Rules. The Division requests that the permittee correct the deficiencies by submission of revised <br />permit pages under appropriate revision applications or by activities on the ground by August 1, 2019. <br /> <br />1. The PAP does not indicate that the shop area has been designated as a permanent facility. Please <br />revise the PAP accordingly. <br />2. A minor revision to update maps in the PAP that show the border between the B Pit area and the <br />long-term spoil area is required or a discussion as to why a revision is not appropriate in this case. <br />3. A minor revision to update maps in the PAP to show that the perimeter ditch on the north side of <br />the site has been designated as a permanent structure is required or a discussion as to why a <br />revision is not appropriate in this case. <br />4. A minor revision to describe and locate new wells related to requirements of the Colorado <br />Department of Public Health and Environment is required or a discussion as to why a revision is <br />not appropriate in this case. <br /> <br />CEC and the Division have discussed the vegetation success criteria in the PAP, namely requirements <br />for the cool season diversity standard and requirement for forbs within the reclamation areas. These <br />discussions are on-going and will likely result in a technical revision application by CEC. <br /> <br />Section VII – Reclamation Liability and Performance Bonding <br /> <br />The Division currently holds a corporate surety in the amount of $1,197,459.85 for the reclamation of <br />the Keenesburg Strip Mine (issued by Travelers Casualty and Surety Co. of America). A compiled <br />reclamation cost estimate was developed by the Division as a part of the RN-07 process issued on <br />September 23, 2017. The Division’s reclamation costs have been updated since that date. A summary <br />of those costs in addition to any revision adjustments has been completed for this Midterm Review. As <br />of the date of this Midterm Review, the Division estimates liability for the current disturbances at the <br />Keenesburg Strip Mine is $1,206,911.00. This amount is sufficient to assure completion of the <br />remaining reclamation work at the site if the work had to be performed by the Division, including the <br />cost of re-establishing vegetation on any revegetated areas, should those areas fail. The updated <br />liability for the Keensburg Strip Mine is $9,451.15 more than the costs of 1,197,459.85, currently held <br />by the Division. <br /> <br />The Division estimates the reclamation liability for mining operations to be $1,206,911.00. Please see <br />the attached Reclamation Cost Estimate. This number has increased since the previous comprehensive