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New Elk Mine, PR5 Adequacy Review 1 <br />September 2, 2021 <br />Page 5 of 6 <br />Rule 2.05.4 — Reclamation Plan <br />37. The Division recently conducted the required Midterm Review (MT8) for the New Elk Mine. Part of the <br />review consisted of a review of the performance bond liability. The Division estimated the reclamation liability <br />at the site to be $5,206,046.00. The current required surety for the New Elk Mine is $4,605,014.08, and the <br />Division currently holds $4,647,856.08 of bond in the form of corporate sureties. The estimated liability at the <br />site based on the MT8 review is $601,031.92 more than the current required surety, and is $558,189.92 more <br />than the current bond held for the site. The Division requests that NECC review the reclamation cost estimate <br />that was attached to midterm review document. Please inform the Division if you concur with the liability <br />estimate. <br />38. Once the cost estimate is finalized, please revised Exhibit 28 with the cost estimate. However, if you do not <br />concur with the Division's estimate please provide a detailed estimate of the cost of reclamation of the proposed <br />operations required to be covered by a performance bond with supporting calculation for the estimate for <br />Exhibit 28. If the latter option is chosen, please provide this estimate as a revision to Exhibit 28. <br />Rule 2.05.6 — Mitigation of Mining Operations <br />(]) Air Pollution Control Plan <br />39. Please review Exhibit 23 and submit an updated copy of the emissions permit if applicable from the Colorado <br />Air Quality Control Commission. <br />(3) Protection of hydrologic balance <br />40. Section 2.05.6(3) of the permit focuses on the protection of the hydrologic balance as it relates to mining in the <br />Apache and Allen Seam. Please revise this section of the permit to account for the revised PR5 mining plan <br />for mining in the Blue Seam. <br />(4) Protection ofparks and historic places <br />41. As discussed above, the SHPO has recommended a class III cultural resource inventory be conducted for the <br />proposed affected area associated with mining in the Blue Seam resulting from subsidence, vibration, and <br />potential surface facilities needed to support mining. The Division acknowledges that no such surface facilities <br />are proposed with PR5 but would note that if additional surface facilities are needed to support mining in the <br />future, appropriate revisions to the permit will be required. Based on the results of the class III cultural resource <br />survey, please provide an update to section 2.05.6(4) of the permit if necessary. If NECC believes the survey <br />is unnecessary, please provide a detailed justification for this. <br />(6) Subsidence Survey, Subsidence Monitoring, and Subsidence Control <br />42. The current approved mining plan proposes retreat mining; however, the PR5 cover letter indicates that no <br />secondary mining (retreat mining) will occur. Please clarify and specifically commit to the mining method <br />chosen. Please revise Section 2.05.6(6) of the permit to account for the revised mining plan proposed with <br />