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Brock Bowles <br />Page 2 <br />May 26, 2015 <br />Division has not issued a proposed decision to approve the SL8 application. I conducted a cost <br />estimate for the remaining reclamation tasks at the site. To conduct this estimate, I reviewed the <br />PR5 cost estimate, the SL8 bond release application, the liability reduction amount calculated for <br />SL8 and the draft findings document for SL8. Based on this information, I determined the <br />liability of the reclamation tasks that remain to be completed for the site. The estimate takes into <br />account the areas that the Division is withholding Phase III bond release approval of with SL8. <br />The remaining tasks include replacing topsoil on areas that have not been approved for Phase II <br />bond release, sealing drill holes, revegetating the remaining areas, site maintenance and <br />equipment mobilization and demobilization. The reclamation cost estimate is enclosed. <br />I recommend that the cost estimate be forwarded to the operator for review and if they disagree <br />with the cost estimate, they should provide a detailed estimated of the remaining tasks as required <br />by Rule 2.05.4(2)(b). <br />2.06.8 Surface Coal Mining and Reclamation Operations on Areas, or Adiacent to Areas, <br />Including Alluvial Valley Floors <br />The permittee's alluvial valley floor (AVF) investigations located in Section 2.06.8 of Tab 21, <br />Volume 6 of the application have been reviewed. The Permit Renewal No. 6 findings was <br />reviewed and it appears the Division has made the determination required by Ruled 2.06.8(3), <br />that the Rapid Creek AVF and the Colorado River AVF exist within and adjacent of the permit <br />area. The permittee has demonstrated that most of the AVFs that were impacted by the operation <br />were affected by coal production mining that was approved and occurred prior to August 3, 1977 <br />which exempts them from the requirements of Rule 2.06.8(a)(i) and (ii). That rule requires that <br />operations not interrupt, preclude, or discontinue farming and not materially damage the quantity <br />and quality of water supplying the alluvial valley floor. According to the RN6 findings the non- <br />exempt portion of the AVFs are located outside of the permit area. Disturbance of the AVF <br />within the Unit Trail Loadout that was within the permit area was Phase III bond released with <br />approval of the bond release application SL7. Rule 2.06.8(5)(a)(iii) does require that the <br />operation comply with the requirements of Rule 4.24 which is discussed in the section below. <br />-No adequacy items were identified for this section. <br />4.05.3(1)-(7) Diversions and Conveyance of Overland Flow and Shallow Ground Water <br />Flow, and Ephemeral Streams Draining a Watershed Less Than One Square Mile. <br />A review of the diversion/drainage designs was conducted for each of the areas discussed in <br />section 2.05.3(4)(d) discussed above. The permanent diversions appear to comply with this Rule; <br />however several adequacy review items were noted: <br />