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<br />costs and eliminating profit and job foreman costs. These assumptions <br />are not in compliance with Rule 3.02.2(1) which states: "The amount of <br />the bond shall be sufficient to ensure the completion of the reclamation <br />plan if the work had to be performed by the Board, through independent <br />contractors, in the event of forfeiture". <br />2. Pursuant to Rule 2.08.5(3)(a)(v), additional revised and updated <br />information required by the Division has not been provided. <br />In the preliminary adequacy review letter (PAR) dated January 10, 1989, <br />the Division identified a number of concerns relating to informational <br />deficiencies and outdated permit documents for the Carbon Junction Mine <br />(see discussion under "History of the Review Process" of this document). <br />Several issues were identified as being of such concern that the Division <br />would not recommend permit renewal until they were adequately addressed. <br />These issues are summarized below, by category. <br />Hydrologic Impact <br />- Annual hydrologic reports including interpretation of data and <br />discussion of any trends or impacts for water years 1986, 1987 and <br />1988 have not been submitted. <br />- An updated probable hydrologic consequences evaluation based on <br />observations made and data collected since permit issuance is <br />necessary. Differences between projected impacts and observed <br />impacts should be identified and discussed, so that the Division <br />can verify any impacts or lack of impacts to the surface and ground <br />water systems, in order to prevent or mitigate material damage. <br />Topsoil Salvage and Replacement <br />- Topsoil balance projections need to be updated based on volumes <br />salvaged to date. Division inspections indicate that substantially <br />more topsoil was salvaged than was originally projected. <br />- Discrepancies regarding proposed disturbance acreage and topsoil <br />replacement depths need to be resolved. This and the previous <br />concern affect both the magnitude of the worst case disturbance for <br />bonding purposes as well as the appropriate topsoil replacement <br />depth. <br />Operation Description <br />- Status of the operation with respect to phase of pit and fill <br />development, facilities construction and projected timeframes needs <br />to be updated. Timeframes as originally projected were disrupted <br />by the long period of inactivity. The permit application text does <br />not accurately reflect the current status of the operation. <br />