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will be removed upon demonstration that reclaimed areas have been adequately stabilized by <br /> vegetation, unless approved as permanent impoundment for the post mining land use. Sediment <br /> ponds that have been approved for permanent retention include Pond 5, Pond 6, Pond 9,Pond 15, <br /> Pond 16, and Pond 17, though per Stipulation No. 39, Ponds 6, 16, and 17, as well as Stock <br /> Tank T22, require approval for permanent retention form the Colorado State Engineer's Office. <br /> Permit History_ and Revisions <br /> Since the last permit renewal RN6 in May of 2017 the permitting actions comprising a proposed change <br /> in liability consist of two bond release requests, SL6 and SL7. Both bond release requests are currently <br /> pending. Information regarding these bond releases is presented in Table 1 below. <br /> Since the RN6 decision was issued,there has been a decrease in bond amount required from $4,929,064 <br /> to the current liability amount of$3,790,697.28. As discussed in below under the heading,Review <br /> Process, and in Section A item 10,the current bond amount held is less than the required liability amount <br /> most recently calculated by the Division. <br /> Table 1: Surety Releases (SL)Proposed <br /> Submittal Proposed Decision Released Proposed Proposed Applicable <br /> Date(s) Area Ph I Released Released Releasable <br /> (acres) Area Ph II Area Ph III Bond <br /> (acres) (acres) <br /> SL6 Under Review at DRMS 0 379.5 816.6 $2,396,812.54 <br /> SL7 Under Review at DRMS 0 367 $1,077,186.14 <br /> SL6 and SL7(Total) $3,473,998.68 <br /> Status of Stipulations <br /> The stipulation history for the Seneca IIW Mine was reviewed with this renewal application. The <br /> review included an investigation of any stipulations imposed, and any responses to existing <br /> stipulations received since the last midterm(MT7) review of August 2018 and associated with <br /> permitting action(MR84). Any stipulations associated with this permit and issued over the life of this <br /> operation which are not discussed in this permit renewal application have been complied with or <br /> terminated. <br /> There is one stipulation still attached to the permit. Stipulation No. 39 was attached to the permit <br /> with the approval of Technical Revision No. 77 (Approved 8 April 2013). Stipulation No. 39 <br /> states: <br /> Division approval of permanent retention of ponds 006, 009, 015, 016, and 017 is <br /> conditioned upon the approval of their retention by the state engineer. Documentation of office <br /> of state engineer approval of ponds 006, 009, 015, 016, and 017 as permanent <br /> impoundments, along with documentation that any necessary water rights have been <br /> obtainedfor the impoundments, shall beprovided to the division prior to approval of any bond <br /> release applicationfor the impoundments. <br /> This stipulation has been partially complied with. Documentation from the Colorado State Engineer's <br /> Office,Department of Water Resources, approving Pond 006, 016 and 017 as permanent structures <br /> remain outstanding. No stipulations are proposed with Permit Renewal No. 7(RN7). For the DRMS <br /> permitting actions associated with granting permanent status please refer to the Section of this document <br /> below. <br /> Page 3 of 37 <br />