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COLORADO LEGACY LAND <br /> M-1977-300 APPLICATION AMENDMENT#6,COMMENT AND RESPONSE SUMMARY TABLE <br /> COMMENT NO. COMMENT RESPONSE TO COMMENT <br /> Exhibit L-Reclamation Costs(Rule 6.4.12): <br /> The Division has the following comments specific to the Water Treatment Plant Operations section: <br /> a. For the Discharge Permit Sampling task,the total cost was reduced from$238,584.00 <br /> to$198,820.00,for100 months of sampling rather than 120 months of sampling,as previously a. Revised as requested. <br /> stated. In this application,the operator is proposing to operate the water treatment plant on a <br /> seasonal basis,up to 6 months per year.The costs associated with operation of the water <br /> treatment plant must cover a 20 year period.Therefore,please revise this task to include costs for <br /> 5 sampling the plant discharge for a total of 120 months. <br /> b. For the Demolish Water Treatment Plant task,the total cost was reduced from$55,000.00 to <br /> $52,016.00.This adjustment appears to be based on the"bid"provided with the operator's last <br /> adequacy response.As noted above,the bid provided is not acceptable for a number of reasons, b. The costs for this task have been revised to match the time and material bid provided by Kessler Reclamation. Please see <br /> including it does not have the contractor name,date prepared,or the appropriate level of detail for response to previous comments for more detail <br /> the scope of work. If the operator is not able to provide an acceptable bid from an independent <br /> contractor for removing the water treatment plant,the Division will require additional <br /> information on the plant(detailed above) in order to calculate a sufficient bond amount for this <br /> task.Based on its experience reviewing and calculating demolition/removal costs for similar <br /> facilities,the Division expects the amount provided for this task will increase. <br /> The Division has the following comments specific to the Alluvial Valley Excavation section: <br /> a. As requested,the operator has added costs for removing and disposing of the upstream cutoff wall a. Revised as requested. The unit cost for each item associated with TR-18 was increased by 31.7%. <br /> and bypass pipeline.These costs are based on the costs that were calculated in association with <br /> 6 Technical Revision No. 18 (TR-18),which was approved in 2011. Given the cumulative rate of <br /> inflation of 31.7%that has occurred since the time of TR-18 approval,the Division will be adding <br /> an additional$30,928.00 (31.7%x$97,565.10)to the total costs provided for these tasks.This will <br /> bring the total costs for these tasks to$128,493.10. <br /> The Division has the following comments specific to the Environmental Monitoring section: <br /> a. For the Groundwater Monitoring task,the total cost was reduced from$404,544.00 to a. Revised as requested. <br /> $144,480.00,for sampling 4 wells and 1 spigot,rather than 13 wells (one well is only monitored <br /> for water levels)and 2 spigots on a quarterly basis over a 10 year period,as previously stated.The <br /> total number of samples was reduced from 560 to 200.The Division realizes that some of the <br /> alluvial groundwater monitoring wells at the site have been rendered inoperative due to the <br /> ongoing alluvial valley excavation project(which removed the soils surrounding these wells). <br /> However,the operator has not yet submitted a revised water monitoring plan and map to <br /> incorporate these changes.Therefore,the bond estimate must continue to include costs for <br /> 7 sampling all approved monitoring locations on a quarterly basis over a 10 year period,until the <br /> approved monitoring plan has been formally updated (through AM-6 or a subsequent Technical <br /> Revision). Please revise this task accordingly. [Please note,if the operator chooses to update the <br /> water monitoring plan and map in AM-6,more than one section of the application may need to be <br /> updated to reflect these changes.] <br /> b. For the Monitoring Well Abandonment task,the total cost was reduced from$50,220.00 b. Revised as requested. <br /> to$25,120.00,for sealing a total of 1,256 linear feet of monitoring wells (at$20/foot),rather than <br /> 2,511 linear feet,as previously stated.It is not clear why the linear footage and associated cost <br /> were revised,as the notes for this task still state that 13 monitoring wells totaling 2,511 linear feet <br /> will be abandoned.The bond estimate must continue to include costs for abandoning all approved <br /> monitoring wells until the monitoring plan has been formally updated and/or a copy of the final <br /> PAGE 6 OF 7 <br />