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-z- <br />The initial permit application was submitted to the Division on <br />February 23, 1982. The Division issued a proposed decision to approve the <br />application on July 5, 1983. Permit C-82-054 was issued on October 25, 1983. <br />The permit was issued for a term of five years and contained 21 stipulations. <br />Mine development activities were initiated at the site shortly after permit <br />issuance. <br />On April 1, 1986, the operator submitted a Notice of Temporary Cessation of <br />Operations to the Division. The Notice stated that the mine had been idle <br />since January, 1986, due to lack of a confirmed contract. The Notice <br />indicated that approximately 106 acres had been disturbed when operations <br />ceased. <br />On April 8, 1986, the Division issued findings of the mid-term review of the <br />Carbon Junction Permit. The review identified a number of issues which <br />required revision or updating and directed the operator to submit a technical <br />revision to resolve the concerns. The issues are listed on pages 8 through 10 <br />of the mi.d-term permit review document. <br />Technical Revision No. 4 was submitted by the operator on February 2, 1987 to <br />address the mid-term review concerns. The revision included certain missing <br />hydrology data and topographic cross-sections. Information pertaining to a <br />number of items of concern identified by the Division in the mid-term review <br />was not included in the technical revision application, but the operator <br />committed to submittal of the information or completion of necessary tasks a <br />minimum of 60 days prior to re-commencement of mine activities. For the most <br />part, items addressed by the commitment involve incorporation of previously <br />approved revisions and updated environmental data into the permit documents, <br />as well as clarification of various aspects of the mining and reclamation <br />plan. The Division approved the technical revision on May 12, 1987. <br />On January 19, 1988 the Division notified Pueblo Coal Incorporated (hereafter <br />PCI) that Permit C-82-054 would expire on October 25, 1988 and further <br />notified them, pursuant to Rule 2.08.5, that a complete application for <br />renewal would need to be submitted to the Division by April 28, 1988 in order <br />to continue operations if the permit were to expire pending a final <br />administrative decision on the renewal application. <br />PCI did not submit a complete renewal application until October 12, 1988, well <br />after the April 28 deadline. As a result, since October 25, 1988, when Permit <br />C-82-054 expired, PCI has been authorized to conduct only limited monitoring <br />and maintenance activities as required to maintain compliance with the Law and <br />Regulations. <br />The Division deemed the renewal application complete on October 20, 1988. <br />On January 10, 1989 the Division issued its preliminary adequacy letter which <br />identified items of concern based on a review of the permit renewal <br />application and associated documents. Issues addressed in the letter included <br />topics not resolved during the mid-term review and additional concerns with <br />