2025-10-07_GENERAL DOCUMENTS - C1982057

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Permit Number: C1982057 Page 14 of 20 Phase III Ponds and stock ponds were designed according to permit as-builts and were in good repair at the time of inspection with spillways and discharge structures functioning adequately. Ponds have received permanent designation from the DRMS. The requested release areas report surface runoff to sediment pond 005 and 006, 015 and 017 and constructed drainages observed were found well armored and stable with established vegetation on banks and grasses taking hold in the channel. The water quality monitoring plan referenced in Tab 15 and associated appendices of the permit document has undergone several updates over the years with an update associated with permitting action such as Technical Revision No. 82 (TR82) in 2016, requesting a reduction in hydrologic monitoring. Several reductions in monitoring were granted with TR82. Additionally, several parameters were suspended in 2010 because of the approval of TR69. Monitoring of several locations previously suspended were re-initiated to support the SL8 application in accordance with the permit requirements. The data resulting from this monitoring was submitted and analyzed in the spring of 2025. As a result, with the approval of TR83, a suspension of groundwater monitoring was requested in April of 2025 in association with this Phase III bond release request and approved by DRMS in August of 2025. Permanent Infrastructure Facilities approved for permanent retention and included within the SL8 application are depicted on Map 3 of the application. Structures left as permanent features include the shop and surrounding area (approximately 2.3 acres), water well and well house located at the shop, power lines and substation, ten fenced shrub plots, sediment ponds, stock ponds, and miscellaneous fences. Permanent Roads Several access and light use roads have been approved as permanent features for the Seneca II West Mine as part of TR68 and TR79. These roads are presented in Attachment 20-2 (Permanent Features) of the approved mine permit application package. For segments of the roads comprising this bond release please see the bond release application and Map 3 for permanent feature locations. Permanent Impoundments Except for the six impoundments included in the SL8 bond release application, all other ponds have been previously released. The following six impoundments were included in the SL8 bond release request: sediment ponds 005, 006, 015, 016 and 017. Per Rule 4.05.9(13), the Division reviewed the permit to determine if the required documentation was included in the permit for each impoundment to remain as a permanent feature. Permanent impoundment demonstrations can be found in Tab 20, Attachments 20-2, Appendix 20-2.1 and 20-2.2 of the permit application package. As shown in the Tab 20 documents, SPL needed to obtain final State Engineer Office (SEO) approval to retain Ponds 006, 016, and 017. On August 25 and 28, 2025, SPL provided the required SEO approval documentation. Therefore, all the remaining ponds have received approval from DRMS to remain as permanent. Vegetation Results The Cedar Creek CCAI Report of Findings, Testing for Revegetation Success for Phase III Bond Release and the application were reviewed for meeting vegetation success standards and data collection methods. Tables 2 and 4, of the CCAI report included in Appendix D of the SL8 application, represent summary tables assessing the