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b. Spillway Crest Elevation <br />c. Spillway Crest Length <br />d. Spillway Head and Freeboard <br />4.03.1(7), 4.03.2(7) and 4.03.3(7) — Haul Road, Access Road and Light Use Road Reclamation <br />There is a discrepancy with the Roads Map, Map 27. Map 27 in Laserfiche is different than the hard copy Map 27 <br />in the permit. The map in Laserfiche is dated later and is likely the correct map. Section 2.05 of the permit discusses <br />roads beginning on page 2.05-14.1, and reclamation of the roads is discussed on page 2.05-31.3. The following <br />adequacy review issues were noted: <br />17. Page 2.05-14.1 cites Map 27A. The Division could not locate this map in our hard and electronic copy of <br />the permit. Please submit this map. <br />4.05.17 — Post -mining and Rehabilitation of Sediment Ponds, Diversions, Impoundments, and Treatment <br />Facilities <br />Pond 9A -P 1 is the only permanent impoundment currently identified in the permit. The performance standards <br />discussed under this rule will apply before the permit area is abandoned. <br />18. Does MCM intend to retain any other structures/features as permanent? If so, they must provide a revision <br />to the reclamation plan and obtain approval from the Division. <br />4.13 — Contemporaneous Reclamation <br />19. The mine is currently in temporary cessation. Rule 4.13 is a performance standard. Should the operation <br />now be considered in permanent cessation? <br />4.25 Operations on Prime Farmland <br />A negative determination for the presence of prime farmland has been made for the Williams Fork Mine. <br />SECTION IV — BONDING SUMMARY <br />The last site wide reclamation cost estimate conducted for this site was with the Permit Renewal No. 6 (RN6) <br />review. Since the approval of RN6, the required liability amount has not changed. The current liability is set at <br />$4,620,949.52. Moffat County Mining currently has a bond in place in the amount of $4,621,000.00. Using the <br />RN6 cost estimate, the Division conducted an update of the reclamation cost based on the most recent unit costs for <br />equipment, equipment operators, etc. The overall reclamation tasks did not change. Based on the updated <br />reclamation cost estimate, the required liability at the site is now set at $5,001,871.44. The reclamation cost estimate <br />is attached. Given this, the permittee will need to increase their surety by $380,871.44. The primary source of the <br />increase in reclamation cost is a result of the cost of revegetation. The previous reclamation cost estimate conducted <br />C1981044 Midterm 2016 Findings.docx Page 9 <br />