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5. It is premature for the Division to consider terminating the <br /> groundwater monitoring program at this point, so a final evaluation of <br /> impacts to groundwater cannot yet be made. If the operator wants to <br /> establish numerical parameter values to be used when applying the <br /> INS at the POC wells in the future, I would encourage them to submit <br /> a Technical Revision with suggested values and a rationale. From my <br /> reading of section 2.05.2 of the PAP it appears that monitoring of GW- <br /> N56, 57 and 58 preceded the mining of any coal at the site, although I <br /> would ask for further clarification on the precise times of the different <br /> stages of disturbance. <br /> The Division's review of Section 2.03 finds that additional detail is needed; <br /> 6. Owner and control: Section 2.03.4(3)(b) "Relationship of the <br /> controlling persons to the applicant:" ERMR has provided begin dates <br /> for Tri-State Board of Directors officers and members. However, only <br /> the year, and sometimes the month and year the individual began their <br /> office is noted. Pleas provide Month, date, and year that officers and <br /> board members began, and/or ended their office. <br /> The Division reviewed and updated the remaining reclamation cost estimate (RCE) <br /> for remaining tasks at the mine site. The RN2 reclamation cost update reflects <br /> increases in equipment and operator costs. The Division has also included <br /> increased cost due to tasks that have been approved since the last reclamation cost <br /> update, SL2 approved 4/25/2019. Tasks that have been removed from the <br /> reclamation plan due to approved revisions (MR28)have been removed from this <br /> estimate. Tasks that have been completed,but have not yet been approved for bond <br /> release remain in the RN2 RCE. The Division is currently reviewing the SL3 <br /> application for New Horizon North. Once a decision has been made on SL3, <br /> associated tasks will be removed or reduced. <br /> 7. RN2 Reclamation Cost Estimate: The total for all remaining tasks at <br /> the New Horizon North Mine is $1,164,762. The Division's estimate <br /> accompanies this letter. The current surety held by the Division for <br /> the New Horizon North Mine is $2,617,883.57. <br /> Please provide the requested updates to Section 2.03.4(3)(b). Please review the RN2 <br /> Reclamation Cost Estimate. If you have any questions regarding the estimate,please let me <br /> know. <br />