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2021-06-15_REVISION - C1981038 (19)
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2021-06-15_REVISION - C1981038 (19)
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Last modified
6/18/2021 8:49:46 AM
Creation date
6/17/2021 8:44:04 AM
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Template:
DRMS Permit Index
Permit No
C1981038
IBM Index Class Name
Revision
Doc Date
6/15/2021
Doc Name
Proposed Decision and Findings of Compliance
From
DRMS
Type & Sequence
SL7
Permit Index Doc Type
Findings
Email Name
RDZ
MAC
Media Type
D
Archive
No
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IV. PROPOSED DECISION <br /> Based on the observations above, the Division proposes to approve BRL's request for a Phase II and III <br /> bond release for the Bowie No. 1 Mine. This proposed decision will release the applicant from liability <br /> for all reclamation work in the ROM area,with the exception of the entrance road. The released area is <br /> 10.38 acres, and the road area that remains is 0.34 acre. <br /> When determining the amount to be released under a bond release request,the Division is required to limit <br /> the release amounts to the percentages allowed under Rule 3.03.1(2), and ensure that the release amount <br /> does not result in the Division holding less bond than would be required to complete reclamation of the <br /> site in the event of a forfeiture (Rule 3.03.1(3)3(d)). Rule 3.03.1(2) allows for a percentage of release of <br /> liability for three phases: <br /> • Phase I release allows for a maximum of 60 percent of the total liability for the subject area. <br /> • Phase II release allows for an additional 25 percent(for total of 85 percent). <br /> • Phase III release allows for an additional 15 percent(for total of 100 percent). <br /> For a given bond release application, the amount is also limited by the size of the subject area. The <br /> Division uses a straight percentage of area requested for release divided by total area. For example, this <br /> application requests Phase III release on 10.38 acres (the original 10.72 acres less 0.34 acre for the road) <br /> out of a total of 97.5 acres for the East Mine. The result is 10.65 percent of the total area. <br /> A review of the minimum bond retention amount, compared to the estimated costs to complete the <br /> remaining tasks for which liability has not been released, indicates that the Division may release the <br /> maximum amount allowed under Rule 3.03.1(2)for this SL-07 bond release request. <br /> The reclamation liability for the Bowie No. 1 Mine prior to any approved bond releases was calculated <br /> with Permit Renewal No.4(RN-04)to be$6,879,590.12. The Division subsequently approved four Minor <br /> Revisions and eleven Technical Revisions prior to any approved bond releases, totaling $118,677.31 in <br /> reclamation liability. The total pre-release liability for the site should therefore have been $6,998,267.43 <br /> ($6,879,590.12+$118,677.31). Unfortunately,approvals of bond release applications SL-02, SL-03,and <br /> SL-04 were based on the $6,879,590.12 amount, instead of the $6,998,267.43 amount. The Division <br /> corrected this with SL-05. Therefore,the determination of maximum release amounts (Table 1)is based <br /> on a total of$6,998,267.43. <br /> The breakdown between the three areas (East Mine, West Mine,and Loadout)is based on details within <br /> the Reclamation Cost Estimate for RN-04. The values for each area/phase combination (e.g., East <br /> Mine/Phase I) are the maximum amounts that should be considered when assessing the appropriate <br /> release of liability for a particular bond release. <br /> Permit Number G1981-038 Page 10 of 14 <br />
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