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New Elk Mine, PR5 Adequacy Review 2 <br /> November 2,2021 <br /> Page 8 of 11 <br /> Superintendent were not accurate. Given this,the Division has revised the <br /> cost estimate and found the revised liability to be $5,218,954.00. <br /> 2. Item b:Tasks 001 to 016(Dozer work)increased by an average of 27%,which <br /> does not appear to be in line with our understanding of the actual cost increase <br /> based on the PPI index. <br /> a. DRMS Response:Please see the response to item#1 above. <br /> 3. Item c:Tasks 019 to 027(Truck work),028 to 029(Demolition work),033 to 049 <br /> (Scraper work),and Tasks 058 to 063(Ripper work)all had increases well above <br /> the amounts that would be expected based on the PPI index. <br /> a. DRMS Response:Please see the response to item 91 above. <br /> 4. Item d:Task 031 (Plug and Seal Boreholes)increased by 93%. <br /> a. DRMS Response:Unfortunately,the error noted in 2018 regarding <br /> equipment costs resulted in a significantly lower costs for drill rigs during <br /> that time and were not reflective of accurate costs. This resulted in a <br /> significant increase in costs in 2021. <br /> 5. Item e:Task 032(Seal addition wells)increased by 74%. <br /> a. DRMS Response: See response to item 94 above. <br /> 6. Item f:Task 051 (Mine Seal)increased by 50%. <br /> a. DRMS Response: These unit costs are provided by DRMS' Inactive Mine <br /> Program and are reflective of their costs. <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 <br /> proposed operations required to be covered by a performance bond with supporting calculation for the <br /> estimate for Exhibit 28. If the latter option is chosen,please provide this estimate as a revision to Exhibit 28. <br /> a. NECC Response: We will review and bond this as part of MT8 and not PR5. <br /> b. DRMS Response:The Division cannot approve PR5 unless the applicant will submit the required <br /> performance bond in accordance with Rule 2.07.60). Please review the updated PR5 cost estimate. <br /> If NECC does not concur with the Division's estimate please provide a detailed estimate of the cost <br /> of reclamation of the proposed operations required to be covered by a performance bond with <br /> supporting calculation for the estimate for Exhibit 28. If NECC concurs with the PR5 cost estimate, <br /> please provide this estimate as a revision to Exhibit 28. <br /> Rule 2.05.6—Mitigation of Mining Operations <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 <br /> the Apache and Allen Seam. Please revise this section of the permit to account for the revised PR5 mining <br /> plan for mining in the Blue Seam. <br /> a. NECC Response: Section 2.05.6(3)has been updated. <br /> b. DRMS Response: <br />