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Rule 3.03.2 (5). Please provide responses with adequate time for the Division to review items prior to the decision <br /> date or,request an extension of the process. <br /> Please find below the adequacy review issues that must be addressed prior to the Division's approval of the <br /> bond release. Please refer to the bold,numbered items <br /> Rules 4.05.2(2),4.05.6(7),4.05.17 <br /> DRMS August 2019: Sedimentation ponds shall be maintained until removal is authorized by the Division and the <br /> disturbed area has been revegetated and stabilized. Upon removal the affected area shall be regraded and <br /> revegetated,unless the pond has been approved for retention as compatible with the approved postmining land use. <br /> Ponds 9AP2,9AP3,and 9AP4,have not been reclaimed and require either: <br /> A designation as permanent stock tanks in support of the postmining land use of rangeland and wildlife habitat or. <br /> 2)complete reclamation of ponds 9AP2,9AP3,and 9AP4. If it is the intention for Moffatt County Mining to permit <br /> the ponds as permanent stock tanks in support of the postmining land use,the existing sediment markers and <br /> headgates must be removed. <br /> 1. Please provide a request for designation via a Technical Revision(TR),to DRMS for incorporation as revised <br /> pages into the permit. <br /> Guidelines: Phase II Bond Release Part 1,Inspection Criteria,Vegetation <br /> DRMS August 2019: Inspection of the bond release parcels identified areas of Bromus tectorum (downy brome or, <br /> cheat grass),identified as a List C noxious species by the Colorado Department of Agriculture that tends to <br /> outcompete desirable species and presents a fire hazard. The allowable relative cover contribution of annual and <br /> biennial species should not exceed 10%cover or 3%of the area of the bond release parcel. DBMS plans additional <br /> field reconnaissance to ascertain a reliable measure of acreage exhibiting contiguous areas of Bromus tectorum. <br /> DRMS will provide the results of this analysis to MCM and other interested parties as soon as possible after the <br /> additional inspection. <br /> Rule 4.15.7(5): The liability period shall reinitiate whenever augmented seeding,planting,or other augmentive work <br /> is required and conducted. Should DBMS determine that augmentive work is required on areas of Bromus tectorum, <br /> the liability period will be reinitiated on those areas. <br /> Guidelines: Selected Bond Release Issues Part 5,Hydrologic Considerations <br /> DRMS August 2019: An evaluation of reclaimed areas with respect to suspended solids entails modeling or a <br /> combination of site specific runoff and sedimentation data for reclaimed watersheds within each bond release block. <br /> Moffat County's application did not include a sedimentology demonstration assessing the contribution of total <br /> suspended solids(TSS), as required for Phase II and Phase III release. This could be achieved through a variety of <br /> methods such as the RUSLE or the Universal Soil Loss Equations and should include a comparison of premining <br /> condition. <br /> 2. Please provide DRMS with the sedimentology demonstration of your choice for each of the bond release blocks, <br /> one for the Strip Pit and one for the Utah Tract. <br /> Williams Fork Mine: Bond Release SL4 Prepared by: R.Reilley <br /> August 2019 Pg 2 <br />