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1� � .COLORADO LEGACY LAND <br /> Costs were inaccurately calculated for caustic soda-the price listed by CLL is only enough for one year of The calculation error in Table L-1 has been corrected. <br /> 10 caustic soda,resulting in a discrepancy of approximately$380,000 over the subsequent 19 years of WTP <br /> operation using CLL's calculation methodology for other annual costs such as barium chloride and <br /> antifoulant. <br /> More description of the assumptions for the"sustaining capital"line item is needed.Useful life of major The sustaining capital costs provided in the table may be applied to assess replacement costs as noted by the reviewer. The costs <br /> assets is not factored into the CLL cost analysis;therefore,it underestimates asset replacement costs and provided in Table L-1 are for a 20-year time period,however WTP operations are limited to 6-months or less.At the present <br /> 11 sustaining capital needs at the WTP over the 20-year period.Examples of likely asset replacements include time,the"run time"of the RO units is less than 3 years,and a there have been only a few minor repairs required,at less than <br /> feed pumps,system pumps,filter housing,electrical components,etc. $2,000 per year. <br /> 12 CLL's cost analysis does not account for rate increases or inflation for key line operational/maintenance Inflation is not a line item in Table L-1 because the total surety amount is adjusted each year for inflation on the previous year's <br /> cost categories such as labor,power,and chemicals. value. This process is done outside of this Amendment comment response process. <br /> There is no contingency plan if uranium and other site contaminants of concern concentrations continue to Please see previous responses to comments regarding contingency planning. <br /> 13 rise,causing more frequent membrane change outs or start-up and operation/maintenance of an ion <br /> exchange treatments stem. <br /> 14 No estimates of use or costs were provided for potable water. As stated in the notes section of Table L-1. Potable water for the bathroom facilities is provided by the onsite water treatment <br /> plant. <br /> Based on these items,the estimated increase in costs could be up to$2 million or more based on our Comment noted. Please see response to Comments#10-13 for line-item responses. <br /> preliminary review of CLL's cost estimate provided in Attachment C.Thus,the costs provided are not <br /> 15 sufficient for operating the water treatment plant for 20 years.Furthermore,the long-term operating <br /> strategy requires pumping the mine pool indefinitely,therefore the costs should account for a longer <br /> assurance time than 20 years. <br /> Lastly,it is not clear why the updated schedule for remaining work or anticipated durations of the The initial surety bond was developed using a consistent 10-year time period. However,in response to previous concerns <br /> remaining work is different for operating the water treatment plant compared to other reclamation expressed by the City of Arvada and Denver Water,and at the direction of DRMS,CLL increased the active Water Treatment Plant <br /> activities such as environmental monitoring or in-situ treatments.Data collection and other reclamation Operations surety basis from 10-years to 20-years because 20-years is the maximum permitted time period for surety bonding. <br /> 16 activities that support the long-term plan for operating the water treatment should be calculated for the CLL also notes that this is a rolling 20-year time period meaning this money would remain in the surety bond as long as current <br /> full period of reclamation.If a reduction in time and/or money is being sought,the existing information active treatment methods are employed. <br /> does not support a conclusion that the"reclamation activities"will achieve a condition consistent with Rule <br /> 3.1 at the end of the reclamation period. <br /> The cost analysis provided herein is not considered a calculation of financial warranty,and addressing the Comment noted. <br /> 17 comments provided above should not result in a reduction in the financial warranty for water treatment <br /> plant operations in the future. <br /> PAGE 12 OF 12 <br />