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<br />2. Legal description in permit application is out-of•date. The legal description in <br />the permit application is no longer accurate. Please provide an updated legal <br />description to ensure compliance with Section ?.03.6. <br />3. Permit does not specify a monitoring program for slump. Future bond release <br />for the slump parcel will depend on a demonstration of structural stability. <br />Historical monitoring data would be necessary in order to make such a <br />demonstration. The permit currently does not describe such a monitoring program; <br />therefore, the Division requests that a monitoring program be specified in the <br />permit application. <br />4. Permit does not accurately describe the hydrologic monitoring plan. The <br />permit application describes the monitoring plan that was followed prior to the <br />recent bond release. To ensure compliance with Section 2.05.6(3)(iv), please <br />update the description of the monitoring plan and explain the technical basis for <br />recent changes in the monitoring plan. <br />5. Permit does not identify current property ownership within and adjoining the <br />permit area. The description of property ownership within and adjoining the <br />permit area is no longer accurate. Please update this information to ensure <br />compliance with 2.10.3(1)(a). <br />6. Permit does not explain the bond release status of the ponds in the permit <br />area. The permit application does not adequately explain the reclamation status of <br />ponds I-1G-8 and 003. The Division has previously approved ponds HG-8 and 003 <br />as permanent ponds The ponds are no longer part of a mine sediment control <br />system, bu[ are watering ponds for wildlife and livestock . The land surrounding <br />the permit area is rangeland. No reclamation liability is associated with the ponds, <br />and the Division anticipates their discharges will be monitored only for NPDES <br />requirements. The 6.8-acre permit area comprises less than l `70 of the ponds' <br />drainage areas. Although the ponds comprise a substantial part of the remaining <br />6.8-acre permit area, the Division effectively has no jurisdiction over the ponds. <br />The sole purpose of maintaining a mining and reclamation permit on the two <br />parcels where the ponds are located is to achieve adequate shrub density. To avoid <br />confusion over the regulatory status of these ponds, the Division requests that an <br />explanation of the ponds' status be inserted in the permit application. <br />Hayden Gulch Mine Page 5 August 11, 1999 <br />Midterm Review <br />