2025-10-07_GENERAL DOCUMENTS - C1982057

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Permit Number: C1982057 Page 13 of 20 Phase III inspected the general configuration of each impoundment to determine if they have been constructed in accordance with the permit. Previous measurements taken by the Division of primary and emergency spillway’s determined that construction was in accordance with the approved plan and permit requirements. All impoundments were functioning as designed at the time of inspection. Backfilling and grading at ponds are not required as ponds are designated and approved as permanent structures. The Division finds that SCC has achieved the requirements for Phase I bond release on 26.9 acres at the Seneca IIW Mine as depicted on Map 1 above. Phase II Finding Rules 3.03.1(2)(b) and (3)(b) Phase II release areas are comprised of roads, ponds and areas around ponds 006, 016 and the slide area above Pond 015. A sedimentology demonstration and vegetative cover analysis were provided for these areas in the application as per Rule 3.03.1(3)(b) and Section III.A.7.a, of the Division's 1995 Guideline Regarding Selected Coal Mine Bond Release Issues. Appendix E, Table 6 of the SL8 application provides a statistical summary of the pre‐mine and post mine total suspended solids (TSS) for the Dry Creek and the Sage Creek watersheds. DRMS found the reclaimed parcels to be stable, well vegetated and with no erosional features indicating sheet flow runoff from the reclaimed site. DRMS deemed the suspended solids demonstration to indicate no material damage to water resources or approved land uses as a result of mining. Cover success is not required for permanent infrastructure. Cover was found to meet the vegetative success standards for both 2022 and 2023 as follows: DRMS finds that successful revegetation for the parameter of cover was demonstrated in both 2022 (42.6%) where 31.9% would meet the standard and 2023 (53.5%) where 45% would meet the standard. Phase III Finding Final vegetation reclamation success was evaluated for vegetative cover, herbaceous productivity, species diversity and woody plant density. Hydrologic impacts to surface and groundwater were also evaluated as was the retention of permanent infrastructure. The evaluation of this bond release application (SL8) included the bond release inspection, a review of the permit requirements and regulatory criteria, and review of past inspection reports, annual reclamation and hydrology reports. During the bond release inspection, participants walked through all parcels requested for bond release making visual assessments of compliance with the requirements as described above in Section II of this document. The 5 June 2025 inspection report details the findings from the inspection. A summary of the observations is discussed below. The bond release inspection comprised an inspection for the remaining areas associated with SL8. Several maintenance items were identified during the inspection comprising small areas of noxious weeds to be treated. All items were addressed by SPL and at the next DRMS inspection (July 2025) of the site were found to have been adequately addressed.