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Chronolo2v of Division's Review of Bond Release Aaalication <br />The Division's review of P & M's bond release application found the application to be technically <br />adequate, as submitted, and therefore the Division had no technical adequacy questions for P & M. <br />The Division conducted an analysis of P & M's hydrologic impacts. The analysis covered data cited <br />in the bond release application and P & M's past annual hydrology reports. <br />On December 4, 2003, the operator requested extension of the origina160-day review deadline to <br />December 19, 2003 to allow the Division additional time to confirm the accuracy ofthe bond release <br />amount. On December 9, 2003, upon request from the Division, the operator submitted revised <br />figures for the acreage in the bond release area and the amount of the bond release request in order to <br />be consistent with previous bond releases. <br />Comments and Obiections <br />The Division received no written objections, or requests for an informal conference regarding the <br />bond release application. Routt County Planning Department phoned the Division on October 7, <br />2003 to confirm the office building next to Oak Creek is not part of the current bond release <br />application. The Planning Department staff member expressed their concern about consistency of <br />approved postmining land use and county zoning. The mine operator was notified of the phone call <br />the next day during the bond release. <br />III. CRITERIA FOR BOND RELEASE <br />Phase I Bond Release <br />Section 3.03.1(2)(a) states, "Up to sixty percent of the applicable bond amount shall be released <br />when the permittee successfully completes backfilling, regrading, and drainage control in accordance <br />with the approved reclamation plan." Section 3.03.1(3)(b) states "No more than sixty (60) percent <br />of the bond shall be released so long as the lands to which the release would be applicable are <br />contributing suspended solids to streamflow or runoffoutside the permit azea in excess of premising <br />levels as determined by baseline data or in excess of levels determined on adjacent nonmined azeas". <br />At the time the bond release area was permitted, there was no requirement for the operator to submit <br />a map or drawing of the proposed postmining topography. The permit contains an approved post- <br />miningtopography map for the bond release azea (Exhibit 3.4-1, Sheet 2), but this map was prepazed <br />long afrer the Goat Trail and conveyor were constructed, and the map does not show topographic <br />contours in the bond release area. The approved reclamation plan for the bond release area calls for <br />removal of conveyor belt structures, the lower tipple facility, and grizzly structure. Regrading is <br />required where structures have been removed. Accumulated coal fines aze to be removed from the <br />conveyor comdor, the fill azea along the uppermost conveyor is to be reshaped, and water bars aze to <br />be placed along the length of the conveyor corridor. As previously explained, the Goat Trail road <br />and lower facilities gravel pad were approved as permanent features in Technical Revision 37. <br />