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<br />Introduction <br />This document presents the results of the Division's mid-term <br />review of the Keenesburg Mine. This mid-term review was conducted <br />to fulfill the requirements of Rules 2.08.3, 2.06.2(9), 2.06.3(4), <br />2.06.5(3), 2.06.7(5) and 3.02.2(4). k~ x <br />Rule 2.08.3 requires that the Division conduct a review of each <br />permit issued, prior to its mid-term (2 1/2 years). Based on this <br />review, for good cause shown, the Division may require reasonable <br />revision or modification of the permit provisions to ensure <br />compliance with the Act and Regulations. <br />Rules 2.06.2, 3, 5, and 7 requires that experimental practices, <br />mountain top removal variances from AOC, and variances from <br />contemporaneous reclamation be reviewed by the Division where <br />applicable. The Keenesburg Mine does not have any operations under <br />these categories. <br />Rules 3.02.3(4) requires that the Division review the amount of <br />bond and the terms of acceptance of the bond every 2 1/2 years. <br />The mid-term review consisted of a detailed review of the <br />Keenesburg Mine application to identify any items that may have <br />been overlooked during the initial review. The Division also <br />reviewed subsequent revisions and stipulation responses to ensure <br />that all permit commitments and conditions were being followed. <br />Hydrologic monitoring data was reviewed in conjunction with the <br />review of the application to assess the adequacy of the monitoring <br />plan and discussion of hydrologic impacts. <br />This document is organized as follows: Section I includes a <br />summary of our decision to require revisions with regard to the <br />mid-term review required under Rule 2.08.3, including a listing by <br />category of what items need to be revised, and a rationale for <br />requiring these revisions. Section II is a summary of the <br />revisions which have been processed during the last five years. <br />Section III presents a summary of the status of the stipulations <br />attached to the Keenesburg Mine Permit No. C-81-028 and any <br />revision required with regard to the stipulations. Section VI <br />presents the result of the bond review required under Rule <br />3.02.2(4)(f). The responses to items identified in Section I <br />should be submitted as one package by February 11, in a format that <br />allows easy insertion into the application. <br />I. Decision to Require Revisions to the Permit <br />The Division has conducted a mid-term review under Rules 2.08.3, <br />2.06.2(9), 2.06.3(4), 2.06.5(3), 2.06.7(5) and 3.02.2(4). The <br />review included the Keenesburg Mine permit application, subsequent <br />revisions, stipulation responses, hydrologic monitoring data, past <br />inspection reports, and on site inspections. The Division finds <br />that certain revisions and modifications are needed to ensure <br />future compliance with the Colorado Surface Coal Mining Reclamation <br />