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gathering and processing the data in the bond release submittal. The review considered the technical <br />validity of the conclusions that CYCC presented in the submittal. The Division also independently <br />analyzed various hydrologic impacts. The Division then compared CYCC's conclusions and the <br />results of the Division's independent analyses to the requirements of CYCC's approved reclamation <br />plan and to the regulatory requirements for Phase III bond release. <br />Chronoloay of Division's Review of Bond Release Application <br />The Division sent adequacy questions to CYCC on December 13, 2001. The questions requested <br />documentation of past grazing, documentation of wildlife habitat enhancement, and clarification of <br />data in the bond release application. The Division received adequate responses on December 18, <br />2001. <br />CYCC's original bond release request was for $1,563,445. The Division notified CYCC by phone <br />on January 3, 2002, that the $1,563,445 amount exceeded the $1,561,099 bond on deposit with the <br />Division. The original request did not account for $2,346 of reclamation liability that had been <br />transferred to Twentymile Coal Company via Minor Revision 88 of permit C-81-071. That liability <br />was for reclamation of a 5-acre storage area. CYCC, by letter dated January 3, 2002, revised its bond <br />release request by $2,346 to match the $1,561,099 bond amount held by the Division. <br />The Division conducted an analysis of CYCC's hydrologic impacts. The analysis covered data in the <br />bond release application and past annual hydrology reports. The results of the analysis are <br />summarized in a memorandum to the SL-08 file dated December 28, 2001 <br />Comments and Objections <br />The Division received no comments, written objections, or requests for an informal conference <br />regarding the bond release application. <br />III. CRITERIA FOR PHASE III RELEASE <br />Phase ID is a final bond release. A Phase ID bond release can occur: <br />No less than 10 years after the last year of augmented seeding, fertilizing, irrigation or other work <br />[Section 3.02.3(2)]; <br />2. When the petmittee has successfully completed all surface coal mining reclamation operations <br />in accordance with the approved reclamation plan [Section 3.03.1(2)(c)]; <br />3. When all reclamation requirements of the Rules and the Act are fully met [Section 3.03.1(4)]; <br />and <br />4. When the final inspection procedures of 3.03.2 have been satisfied [Section 3.03.1(2)(c)]. <br />Mine 1 and the Eckman Park Mine Page 5 January 3, 2002 <br />Phase III Bond Release <br />