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Rec:~r~s Review <br />The review of the surface/ground water baseline and monitoring program data does <br />not reveal anomalies or adverse impacts on the hydrologic regime up to this <br />time. The last ground water monitoring occurred on August 5, 1991. Of concern, <br />however, is the approval of a Technical Reviston by MLRD that allowes the <br />permittee to discontinue his ground water monitoring program. In fact, after the <br />sample collection of 8-6-91 the permtttee capped and sealed all ground water <br />wells, including the AVF locations. Both Phase II and Phase III releases(the <br />latter nqt occurring for at least 10 years) require a finding by the regulatory <br />authority that impacts to the hydrologic regime have not occurred. How can MLRD, <br />ten years hence, make such a finding without up to date data? Thia concern will <br />be forwarded to the Regulatory Program Branch of the Albuquerque Field Office <br />for Further review: <br />The public notice was published in the Pagosa Springs Sun starting on July 11, <br />1991 and for four consecutive weeks thereafter..A check of the Archuleta County <br />Clerk's Office revealed that a copy of the Bond Release application was on Eite <br />as required. Nottflcattan bE intent to release bond had been sent to all parties <br />as required: <br />There are no otitstanding.reclamatlon related violations for this site. AML <br />reclamation fees have been reported and paid through the last reporting quarter. <br />Findings <br />As discussed above, the majority of this site Ls eligible for a Phase I release. <br />However,.as also diseased above, a number of concerns still need to be <br />addressed: AFO can concurr in a decision to approve Phase I Bond if those areas <br />discussed above are removed from consideration and the re-calculation of bond tb <br />be retained clearly establishes the costs of third party reclamation of those <br />areas. <br /> <br />