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SL-2 PHASE 1 BOND RELEASE ADEQUACY REVIEW Several of the maps included in the band release application appear to include a combination of "as built" topography reflecting survey of the areas reclaimed in 2002, as well as "proposed topography", that does not reflect existing ground conditions. For example, Exhibit 9C contains the notation "Topography of reclaimed areas provided by Data Mapping of Grand Junction, CO. (2002)." However, it is apparent that not all of the topography is "as built", because the map shows proposed future topography for reclaimed Ponds 6 and 10 and the Coal Creek channel, and the proposed re-channelization of Coal Gulch. This somewhat confusing situation also occurs on bond release Exhibits 6C, and 60. Please amend or replace these maps as appropriate to clearly distinguish between "as built" and "proposed" topography. It may be appropriate to use "B Series" sediment control maps for the current "as built" situation, rather than the "C Series" post mining topography maps (which was previously done for the North Portal reclamation area). 2. Design information for the RSRDA North Collection Ditch was recently provided within a TR-42 adequacy response submittal. P.E. certification documenting that the ditch was constructed as designed will need to be provided prior to issuance of a proposed approval decision for the Phase 1 bond release. Please provide the requested P.E. certification. 3. Powderhorn Coal Company (PCC) had previously submitted an application for Phase I bond release covering many of the same areas included in this bond release application submitted by Snowcap Coal Company. The PCC application was ultimately withdrawn, however the Division did conduct an inspection associated with review of the PCC application (Inspection Report dated September 28, 2001). Pages 7 and 8 of the inspection report contained discussion of the North Decline permanent channel, including description of P.E. certification and measurements made by DMG. The channel as constructed includes ditch/berms along either side of the channel, which are necessary to divert reclaimed area runoff away from the channel, and into approved sediment control structures. The berms are not depicted on the design channel cross sections of Exhibit 21, although ditches are depicted on Exhibit 12C. Based on the approved cross sections and prudent practice, it is not appropriate that berms be utilized to provide the necessary channel capacity. In addition, it is necessary that the berms be removed or that "berm break" inlets be provided in appropriate locations to allow surface drainage to enter the channel, upon approval of sediment control removal by the Division. Permit text on page 74-3 states that berm breaks will be installed at appropriate locations following such approval. This statement could be seen to conflict with the notation on Exhibit 12C, that "All Drainage Structures except the permanent stream channel and the North most C.M.P. on Access Road No. 2 will be removed prior to final bond releaseU It would appear based on information provided in the P.E. certification and based on the measurements referenced in the September 28, 2001 inspection report, that the channel has adequate capacity to pass the design flow with 6" of freeboard, without reliance on the berms. However, this is not specifically addressed in the certification. Please amend permit Exhibit 12C to depict the location of permanent channel berm breaks, to be implemented upon approval of removal of sediment control structures,