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III. COMMENTS-COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made during the <br /> inspection. Comments also describe any enforcement actions taken during the inspection and the facts or <br /> evidence supporting the enforcement action. <br /> 12. The three underdrain pipes should be cut back to ground level and the pipe outlets covered with rocks. <br /> 13. Mine signs and surface disturbance markers need to be removed at final bond release. <br /> Bond Release Process <br /> The process of releasing the reclamation liability bond for a mine site involves three phases. At Phase I, up to <br /> sixty percent of the total reclamation bond can be released for successful completion of structural demolition, <br /> backfilling and grading and drainage control as required by the approved plan. At Phase II, up to 85 percent of <br /> the total reclamation bond can be released for topsoil replacement and for successful establishment of vegetation <br /> which supports the approved post mining land use and which meets the approved success standard for cover. In <br /> addition,a demonstration must be made that shows that the reclaimed site doesn't contribute suspended solids in <br /> excess of those of pre-mining conditions or of adjacent and comparable non-mined areas. At Phase III,the <br /> remaining reclamation bond can be released upon completion of all of the reclamation work, but not before a <br /> period of ten years has passed after the last augmented seeding, fertilizing, irrigation or other work. <br /> There are additional considerations in the bond release process. One consideration is that no more than sixty <br /> percent of the reclamation bond can be released if the suspended solids level from the reclaimed area is greater <br /> than that of pre-mining levels or from adjacent, undisturbed areas. Another consideration is that the Division can <br /> not release any reclamation bond that would result in insufficient funds to finish the remaining reclamation work. <br /> The operator must submit a formal request to the Division for each reclamation bond release phase.Notification <br /> of the bond release request is made with the publication of a public notice and with notification letters sent to <br /> adjoining landowners, surface owners and various local government agencies. When the Division calls the <br /> submittal complete,a field inspection and evaluation is conducted to determine the status of the reclamation work <br /> that was performed. The field inspection and evaluation are to be held within thirty days of completeness or as <br /> soon as weather permits thereafter.Notification letters for the field inspection must be sent to the surface owner <br /> and agent or lessee. <br /> The inspection and evaluation report is to be made available to the public at the Division's offices. Objections to <br /> the bond release may be made within thirty days of the submittal completeness date or within thirty days of the <br /> completed field inspection. After this initial objection process has been completed,the Division makes its <br /> proposed decision. The proposed decision is made by the Division as to whether to release or not to release all or <br /> a portion of the reclamation bond. Written notification of the proposed decision is sent to the permittee,the surety <br /> company and interested parties. The written notification details in a findings document the reasons for the <br /> proposed decision, provides recommendations for any additional work needed to complete the bond release and <br /> informs the parties of their right to appeal the proposed decision. The Division also publishes the proposed <br /> decision in a public notice. <br /> Blue Ribbon Mine Bond Release Permitting Process <br /> Minrec, Inc. submitted the Phase II and III Bond Release request(SL-2)for the Blue Ribbon Mine in an initial <br /> submittal dated June 4,2008. The certification statement for the reclamation activities performed at the mine <br /> Page 2 <br />