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3 <br />complimentary to that adjacent to the mine. Surface water drainage within the reclaimed <br />parcels is consistent with the sheet flow drainage observed adjacent on undisturbed areas. <br />The drainage pattern of the sheet flow is northeast, again consistent with the surrounding <br />undisturbed areas. <br />CEC does understand the Division's concern with the language of page 114 of the <br />application addressing a specific measure of accuracy for backfilling. As this type of <br />specific commitment does not appear in other mining and reclamation permits approved by <br />the Division, CEC is removing this specific commitment from the Keenesburg Mine <br />Mining and Reclamation Plan under the revisions proposed during the renewal. To further <br />assist the Division in evaluating the post-mining topography, a revised map of the mine has <br />been submitted (the enclosed copies replace Plate 1, "Post-Mining Contour Map", <br />9/25/96) which indicates only the existing topography in the reclaimed and non-reclaimed <br />areas. <br />(2) Bond Release Amount <br />CDMG has indicated, "Documentation in support of the amount requested for release and <br />for work necessary to reclaim the remaining disturbances to an approved Post-Mining <br />Reclamation Plan [sic] is required." <br />CRS 34-33-125(1) and Rule 3.03.2(1) specify the contents of a bond release application. <br />There is no requirement for the bond release application to contain the above requested <br />information. <br />CEC provided the Division with information relating to current site specific conditions, <br />such as current remaining overburden volumes and topsand volumes within the context of <br />the permit renewal process. <br />CEC agrees that there appears to be a discrepancy in reclaimed acreages. The submitted <br />drawings which identify the Phase I and Phase II areas are correct in the identification of <br />the areas requested for release. CEC has recalculated the acreages, and is submitting a <br />revised page 1 of the Application to correctly identify the "Area Requested for Release". <br />(3) Hydrology Issues <br />CDMG is concerned that surface water runoff is commingled with runoff from disturbed <br />areas of the mine site. Additionally, there is a concern about drainage patterns within the <br />reclaimed and unreclaimed areas. <br />CEC is unsure of the nature of the Division's concern. There is no prohibition of the <br />commingling of surface runoff waters in the statute or CDMG regulations. Observed <br />surface water runoff, being infrequent, generally occurs as sheetflow or very shallow flows <br />to the sediment pond. As discussed in the response to question 1, there were no <br />developed surface water drainages prior to mining and there will only be shallow drainage <br />