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COLORADO LEGACY LAND <br /> building and associated structures for final reclamation is consistent with local land use and zoning laws. <br /> Therefore,please add these costs back to the bond estimate or provide the required demonstration. <br /> b.The costs for Caustic Soda (Sodium Hydroxide,Liquid 25%)is said to cover a total of 66,720 pounds(for b. The excel version of Table L-1 was truncating the chemical costs and displaying it as$0.30/lb. The number of significant <br /> 6 months of operation)at$0.30 per pound,for a total of$19,682.40.Based on the information provided, figures has been reformatted to show the correct pricing as$0.295/lb, <br /> the Division estimates the total costs for this task are$20,016.00.Please correct this error in the total cost. <br /> Exhibit L-Reclamation Costs(Rule 6.4.12): <br /> 19 The Division has the following comments specific to the In-Situ Treatment section: <br /> a.The operator's initial bond estimate included costs for six months of Mine Pool Sampling following an The current water quality monitoring plan stipulates that CLL will conduct quarterly monitoring of the mine pool along with <br /> injection,at$950.00 per month(for 5 additional injections over a 10 year period).The Division could not other surface and groundwater locations in the monitoring network. Data from these samples shall be used to monitor in-situ <br /> find this task in the revised estimate.Please explain why these costs were removed. treatment. <br /> Exhibit L-Reclamation Costs(Rule 6.4.12): <br /> The Division has the following comments specific to the Alluvial Valley Excavation section: <br /> a.For the Excavate and Place Soil Onsite task,the operator did not provide the information requested in a. Correct,the operator believes there is enough"clean"material available in the valley where the excavation project is <br /> the Division's adequacy item#35(c).The Division had asked where exactly the fill material will be obtained occurring to regrade disturbed areas and achieve the final reclamation grade. The operator performed a survey of the <br /> from on site,whether the estimated 0.585 acre of disturbance requiring fill pertains only to the South Zone, excavation project area to confirm that there will be enough"clean"soil available to regrade the valley in a manner that <br /> and how the operator chose an average depth of 2 feet(for a total of 6,256 CY)when the excavation depth creates positive drainage to the creek. A map showing the anticipated horizontal extent of the valley is shown on Figure <br /> in the valley is said to vary from 0 to 10 feet.The operator's response states"suitable fill material shall be E-2 and additional text describing the alluvial valley excavation project has been added to Exhibit E. <br /> sourced from the alluvial valley itself'and"CLL intends to regrade the alluvial valley consistent with the <br /> surrounding slopes by pushing adjacent fill materials to fill in excavated pot holes".This response indicates <br /> the operator believes there is enough"clean"material available in the valley where the excavation project <br /> is occurring to merely regrade disturbed areas to achieve the final reclamation grade.Has the operator <br /> performed a survey of the excavation project area to confirm there will be enough"clean"soil available to <br /> regrade the valley in a manner that creates positive drainage to the creek?In order for the Division to <br /> calculate the bond estimate for regrading(rather than backfilling)the disturbed valley areas for <br /> reclamation,additional information is needed.Please provide an approximate total acreage that will <br /> require regrading and an average push distance for each of the two main excavation areas(north and south <br /> zones). <br /> 20 b.The operator has added a line item in this section for Remove 18-in Bypass Pipeline,in accordance with b. CLL intends to leave the bypass pipeline at the site,so costs for its removal have been deleted from Table L-1. <br /> the proposed reclamation plan.Because the operator provided a lump sum estimate of$8,000.00 for this <br /> task,it is not clear if this estimate includes demolition/removal costs for the two bollards or disposal costs <br /> for all of these materials.Please provide a breakdown of this estimate or submit a copy of the bid prepared <br /> by Kessler Reclamation and Construction.Where is the anticipated disposal location for these materials? <br /> c. Please see response to Comment#2. The cut-off wall and riprap/grouted boulder areas were permitted as permanent <br /> c.The Division has requested additional information in Exhibit F regarding any additional structures structures. CLL intends to leave them in place. <br /> associated with the creek(e.g.,upgradient cutoff wall,riprap/grouted boulder areas)which will be <br /> removed for reclamation.Please be sure to add costs for reclaiming any such structures in this section,as <br /> needed. <br /> d. The operator believes there is enough"clean"plant growth medium/topsoil material available in the valley where the <br /> d.For the Top Soil/Plant Growth Medium task,the operator did not provide the information requested in excavation project is occurring to regrade disturbed areas,achieve the final reclamation grade,and support vegetative <br /> the Division's adequacy item#35(d).The Division had asked where exactly the growth medium will be growth(e.g.,seed mix/trees/shrubs),therefor no imported topsoil is required for reclamation. These soils have <br /> obtained from on site,whether any topsoil would need to be imported for reclamation,whether the successfully been used to support vegetative growth and cover at the site previously(e.g.,the North and South Waste <br /> estimated 0.585 acre of disturbance covers all disturbed areas in the valley which will require topsoil Rock Piles). The operator performed a survey of the excavation project area to confirm that there will be enough"clean" <br /> replacement,and how replacing only 3 inches of topsoil will be sufficient to achieve successful soil available to regrade the valley in a manner that creates positive drainage to the creek. A map showing the <br /> revegetation.The operator's response is exactly the same as its response to the Division's question anticipated horizontal extent of the valley is shown on Figure E-2 and additional text describing the alluvial valley <br /> regarding fill material,stating"suitable fill material shall be sourced from the alluvial valley itself'and"CLL excavation project has been added to Exhibit E. <br /> intends to regrade the alluvial valley consistent with the surrounding slopes by pushing adjacent fill <br /> materials to fill in excavated pot holes".Is this an error?Theoperator also removed all costs from the bond <br /> PAGE 7 OF 12 <br />