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Technical Review <br />The Division reviewed technical aspects of the operator's bond release submittal in order to <br />determine if the requested bond release is warranted. The review evaluated the methods that the <br />operator used in gathering and processing the data in the bond release application. The review <br />considered the technical validity of the conclusions the operator presented in the application. The <br />Division also independently analyzed various hydrologic impacts. The Division then compared the <br />operator's conclusions and the results ofthe Division's independent analyses to the requirements of <br />the operator's approved reclamation plan and to the regulatory requirements for bond release. <br />Division's Review of the Bond Release Application <br />The Division's review of the operator's bond release application found two technical adequacy <br />items. Abandonment reports for monitoring wells were needed for the Division's files, and gully <br />erosion in the bond release azea required work on new and pre-existing diversions. The Division <br />received the abandonment reports on December 15, 2004. The erosion control work was <br />accomplished under Technical Revision 34 and Minor Revision 53 of the permit application and in <br />satisfaction of Section 4.05.17 (this work is discussed further under Erosional Stability, below). <br />The Division has received no written objections, nor any requests for an informal conference <br />regazding the bond release application. <br />III. CRITERIA FOR BOND RELEASE <br />Phase III Bond Release <br />Phase III is a final bond release. The entire permit area is being considered for Phase III release. A <br />Phase III bond release can occur: <br />1. When the minimum period of liability of 10 years is met. [Section 3.02.3(2)(b)]; <br />2. When the permittee has successfully completed all surface coal mining reclamation <br />operations 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 aze fully met [Section <br />3.03.1(4)]; and <br />4. When the final inspection and evaluation procedures of Section 3.03.2 have been <br />satisfied [Section 3.03.1(2)(c)]. <br />