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iii iiiiiiiiiiiu iii 999 MINED LAND RECLAMATION DIVISION Department of Natural Resources 7373 Sherman S1., Room 275 Denver, CO 802D3 303 666.3567 Fnx: 303 832-8706 OF. Cpl ~~ r ~ le'!6 ~ Boy Rgn¢r, Govengr Fretl B Bania, Drv15~00 Dneaor July 2, 1990 Mr, Robbie Willson Peabody Development Company 1300 South Yale Flagstaff, AZ 86001 Re: Completeness and Adequacy Review, Exploration Project CX-90-166-23, Seneca II-West/toast Monitor Wells Dear Mr. Willson: Your application to conduct exploration was received in our office on June 13, 1990, Per Rule 2.02.2(3), the Division must make a determination of the application's completeness. We must also decide whether the project will substantially disturb the natural land surface and, if so, whether the proposed activity qualifies as coal exploration or surface coal mining operations. The Division has found that: ., As defined under Rule 1.04(22), the proposed project qualifies as coal exploration involving removal of 250 torts or less of coal; 2, As defined in Rule 1.04(127), the proposed project will result in substantial disturbance to the land surface thus requiring submittal of a reclamation bond and compliance with Rule 4.21; 3. According to the requirements of Rule 2.02.2(2), the notice is complete. To speed the review process, your application was also reviewed for adequacy and the following questions arose: 1, Bonding calculations were reviewed and we discussed these calculations on June 26, 1990. The proposed bond amount of 510,400.00 was found to be inadequate because it failed to account for "worst-case, third party contractor" reclamation as the Division would perform it. Specifically, the bond calculations did not account for mobilization and demobilization costs and reclamation of well recirculating pits in the event they were needed. With these costs added, it was agreed that the reclamation bond would total E12,500.00. STATE OF COLORADO