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Preliminary Adequacy Review Bear Coal Co., Inc. - Bear Mine Page Six 3. Are the stock ponds indicated on Drawing No. 2.09.7(2)(a)-1 (ff. page 47) proposed as permanent impoundments? If so, they must conform to performance standard 4.05.9. 2.05.5 Topsoil The topsoil concerns are expressed in Section 2.05.4(2)(d). 2.05.8 6 .9 Coal Processing Waste, Non-Coal Processing Waste and Underground Development Waste The permit application observes that refuse disposal rules are not applicable (page 66 and 67). However, staff site inspections and examinations of existing stereo- graphic aerial photography of the Bear Coal Mine site suggests that some refuse has been deposited on site. Further, the application also states: "Coal cleaned up at the mine site will be sold prior to the final covering of the disposal area." (page 67) Any waste now on the site will have to be properly addressed within the application. 2.05.4 (2) (a) Reclamation Timetable 1. The applicant states, on page 68 of the application, that "ARCO may wish to succeed the Bear Coal Company, thereby assuming responsibility for reclamation of the disturbed areas." Atlantic Richfield Company has indicated that this is not the case, and that they do not wish to utilize the present surface facilities of the Bear Coal Company. The applicant should verify that Bear Coal Company is responsible for reclamation of the presently disturbed areas. 2. In light of the fact that Bear Coal Company may be ceasing operations in the summer of 1982, the detailed timetable for the completion of each major step in the reclamation plan, including sealin_q of portals, equipment and facilities removal, clean-up, backfilling and grading, seeding, etc., must be submitted. The anticipated starting date and duration of each step in the reclamation process should be included. 2.05.4 (2)(b) Reclamation Cost 1. Supporting calculations must be provided for cost figures supplied in Table 2.05.9(2)(b)-1. The table on Reclamation Cost Estimates is insufficient in suppluinq information needed for the calculation of the reclamation bond. Information which should be provided with supporting calculations is based upon a worst case situation and includes yardage of material to be moved, average haul distances, equipment to be used (make and model numbers), topsoil volumes, seed costs, cost of portal sealing, building removeZ, equipment time needed with specific reference (i.e., Caterpillar Performance Handbook), identification of all assumptions and correction factors, equipment cost (or rental), operating cost per hour, fuel cost, and labor. Calculation of the bond is a critical issue in the permitting process. This information is necessary for determining costs accurately if the State were placed in a position where it was responsible for completing reclamation.