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SCC Seneca II Mine, Phase II bond release (SL-3) pg. 2
<br />OSM received a letter from the BLM concurring with the Phase II bond release on April
<br />29, 2009 (copy attached). No other federal, state, or local government agencies are
<br />required to provide a concurrence for this bond release action. The DRMS did not
<br />receive any comments, written objections, or requests for an informal conference
<br />regarding this Phase II (SL-3) bond release application for the Seneca II Mine. The
<br />DRMS's Proposed Decision documents the applicant's compliance with the Colorado
<br />approved regulatory program at Rule 3.03.2 and DRMS's bond release guidelines dated
<br />April, 18, 1995. Bond release criteria found in the above regulatory provisions have been
<br />met or exceeded by the permittee.
<br />OSM has reviewed DRMS's Proposed Decision document and bond release inspection
<br />report, as well as other pertinent documentation including maps, photographs, and the
<br />public notice. This SL-3 Phase II bond release is limited to those portions of interim and
<br />permanent program lands that were previously granted Phase I bond release, SL-l, on
<br />December 27, 2006. In SL-3, SCC initially requested Phase II release on 1,793.5 acres of
<br />interim [311.1 acres] and permanent [1,482.4] program reclaimed lands. However,
<br />additional adequacy concerns and deficiencies identified during DRMS' review of the
<br />application resulted in SCC withdrawing 580.4 acres of permanent program reclaimed
<br />lands thus reducing the release request area to 1,213.1 acres. During the SL-3, Phase II
<br />bond release inspection DRMS made observations and findings on the following specific
<br />evaluation/inspection topics: results of past monthly inspections, surface and ground
<br />water pollution assessment, erosional features and stability of reclaimed lands, topsoil
<br />replacement thickness, vegetative cover and "bare area" assessment, species composition
<br />and diversity evaluation, condition of sediment ponds, construction and performance of
<br />permanent impoundments, and suspended solids demonstration. Based upon a review of
<br />the mine permit, the bond release application, and site inspections, DRMS found that
<br />SCC has complied with all requirements of Phase II bond release and recommends
<br />approval. OSM finds SCC has met or exceeded the requirements for Phase II bond
<br />release criteria for interim and permanent program reclaimed lands on 1,213.1 acres of
<br />the 1,793.5 acres originally requested for release.
<br />The DRMS currently holds a corporate surety reclamation bond in the amount of
<br />$7,183,489.00 for the Seneca II Mine. Of this total bond amount $6,026,360.00 applies
<br />to the interim and permanent program areas. As noted above, this Phase II bond release
<br />applies to 1,213.1 acres of reclaimed disturbance which includes both interim and
<br />permanent program reclaimed lands. The DRMS proposes to release $1,975,695.00 and
<br />has determined that the remaining bond amount of $4,050,665.00 is sufficient to
<br />complete all remaining reclamation work at the site if it were to be completed by a third
<br />party contractor. OSM concurs with these amounts. Thus, DRMS's proposed release of
<br />$1,975,695.00 from the current bond amount retains sufficient bond to cover revegetation
<br />costs within the proposed release area until final Phase III bond release is approved and
<br />ensures that all remaining reclamation requirements will be completed at the Seneca II
<br />Mine, Permit No. C-1980-005.
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