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Jerry M. Nettleton <br />Page 14 <br />June 11, 2014 <br />Also potential development is planned in this area as depicted on Map 423 and <br />424 of both the "F" and "E" seam for the life of the mine. Please revise this <br />information. <br />ii. Permit Section 2.06.8 needs to be updated to account for subsequent mining and <br />development since the first permit term. <br />Reclamation Cost Estimate; Response to MCM Bonding Review Comments Memo Included with <br />TR36 <br />The Division has conducted a review of the reclamation cost estimate as requested. The current liability <br />set for the mine is $3,590,971.00. This was the estimated cost based on the Midterm Review No. 6 <br />(MT6) conducted by the Division on June 28, 2011. MCM bond review comment memorandum <br />submitted with TR36 indicates the most recent liability amount is $3,464,926.00 which is incorrect. It <br />appears this amount was the revised liability estimate set during the review of Technical Revision No. 34 <br />(TR34) approved on November 16, 2007. However, the liability amount from TR34 has been carried <br />over to the proposed decision form for MR50 approved on February 27, 2013. This is likely due to a <br />coding error in the Division permit tracking system. <br />Given that the actual liability amount is $3,590,971.00 from the most recent cost estimate conducted for <br />MT6, the increase in costs for RN6 are not as significant as portrayed in the bond review comment memo <br />MCM submitted with TR36. <br />1) MCM Concern Task 001: Demolish and Remove all Structures - +$180K (2501o) <br />a) DRMS Response: The MT6 total cost for Task 001 was estimated to be $866,069.52. The RN6 <br />estimate for Task 001 was $887,305.42 which is $21,235.90 more than the MT6 cost. This is <br />about a 2.5% increase from the MT6 estimate conducted in 2011. However, it appears the hours <br />associated with this task is significantly different that what was estimated in during the Permit <br />Renewal No. 5 (RN5) estimate which impacts the Job Superintendent hours and cost. It is likely <br />the hours will need to be adjusted. <br />Upon further review of this task, it became clear the Mine Facilities section of the revised section <br />2.05.3 of the permit may not be a complete and accurate list of structures that exist at the site or <br />have existed at the site utilized for the mine operation that have not been released from financial <br />liability. Revised section 2.05.3 of the permit provides a list of facilities and structures at the site <br />along with a narrative description of the location, use and status of the facility. Many structures <br />discussed in this section are not depicted and/or labeled on Map 25 (Structures and Renewable <br />Resources Map), listed on Table 56 (Existing Structures) or accounted for /listed in the currently <br />approved Exhibit 25 (Reclamation Bond). It is difficult to make a direct comparison with permit <br />section 2.05.3, Map 25, Table 56 and Exhibit 25 as it is possible some structures are called <br />