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stipulations associated with C-1981-013 and issued over the life of the operation which are not <br />discussed in the mid-term review have been complied with or terminated. <br /> <br />No stipulations have been terminated or added to Permit C-1981-013 since the last permit <br />renewal (RN-05). <br /> <br />SECTION IV – MIDTERM ADEQUACY QUESTIONS <br /> <br />Pursuant to 2.08.3, the Division finds that the permit application C-1981-013 contains two <br />deficiencies following the review for the purpose of fulfilling the requirements of the Colorado <br />Surface Coal Mining Reclamation Act, and the Regulations of the Colorado Mined Land <br />Reclamation Board for Coal Mining. The Division requests that the permittee correct the <br />deficiencies by submission of revised permit pages under appropriate revision applications, or by <br />activities on the ground, by July 13, 2012. <br /> <br />Please ensure that the <br />Item 1: Rule 2.03.4(6). Map 1, Map 2, Attachment 1A, Attachment 1B, <br />status of surface and mineral ownership is up to date, with all addresses and information <br />correct. <br />Item 2: Rule 4.05.13(1)(e) and 4.07, Through Permit Revision PR-02 of CDRMS Permit No. C- <br />1981-012, the New Elk Mine assumed responsibility of groundwater monitoring wells NM20, <br />NM21, NM22, NM23, and SF-2. These monitoring wells and information pertaining to these <br />wells are listed in the Golden Eagle Permit on pages 2.05-47b, 2.05-47c, and 2.05-47f. In <br />addition, the transferred wells are identified in the most up-to-date cost estimate, along with well <br />Please update the above referenced pages to reflect the transfer of the five wells <br />LA-218. <br />mentioned. In addition, please provide information as to the status of well LA-218. <br />Golden Eagle permit has approved reclamation success revegetation sampling methods in PAP <br />section 2.05.4. However, the approved method for vegetation productivity sampling consists of <br />2 <br />sampling six 0.1 M quadrats along each 25 M long cover transect. Vegetative productivity <br />results from 2005 and 2006 sampling events for the SL6 application did not achieve sample <br />adequacy. The Division finds the size of the production quadrats unusually small for the type of <br />vegetation being sampled. The Division more commonly sees productivity sample quadrats on <br />22 <br />the order of 0.5 M to 1 Mfor sampling similar vegetation communities. <br /> <br />Item 3:The small size of the productivity sample plots need to be enlarged to bring the sample <br /> <br />methodology into agreement with Rule 4.15.11(b)(i). Quadrat size should be a minimum of ¼ <br />2 <br />NECC will need <br />M and large enough to encompass plants of the larger species being sampled. <br />to submit a proposed change to the sampling methodology as a technical revision. <br /> <br />Reclamation success sample methodology for vegetative cover was approved when the permit <br />consisted of a much larger area prior to SL6 and subsequent permit area reduction. The <br />vegetative cover sampling methods were approved to collect randomly distributed 25 M cover <br />transects. Following the Division’s approval of SL6 (8/26/2008), the remaining area of <br />reclamation liability consists of 1.2 acres of the reclaimed NW Ventilation fan site, reclaimed <br />pad and associated reclaimed access road. The Division is concerned about applying the <br />Golden Eagle Mine -5- 4/4/2012 <br />