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Sent By: cEA1EX; <br />3038232199; Ater-10-03 5:12PA1; Pege 3 <br />more than 65 percent of the estimated value of such property. Hence, the estimated salvage <br />value minus tbe costs for contractor profit and admtn:ct'nhve costs, woaid be further <br />reduced by a factor of .85 before being applied to the amount o€ tequirrd bond. <br />CEMEX will need to comply with the trgtutements of Rule 4.12 if salvage credit is used to <br />off set costs within the tecIamation cost estimate. Withotrt fu[1 compliance, the cost to <br />remove these structures will need to be included in the estimate. <br />2. Banks and Gesso presented two estimates for demolishing the plant area. Cost Estimate A <br />assumes that all concxere is crushed to various sizes, and that the material is sold as <br />aggrogate for a total cost of 53.9 million. Cost Estimate B includes a total cost of the <br />demolition and reclamation assuming that all material is demolished, stockpiled and coverrd <br />end rho arra is revegetated. Cost Estimate B totals 54.6 million. CBM&X has agreed to <br />submit 53.9 million, which mIlrcts the cost associated with crushing sad selling the material <br />as an aggregate product. Please be aware that the iutenL of~the financial warranty is to insutz <br />that the State of Colorado has t1AC nocca5ary funds to complete trclamatiott in accordance <br />. with the approved mining and reclamation plan in the event the band is forkited. The <br />Division is unable to accept art estimate that requires the State of Colorado to process <br />material to be gold as aggregate, than in tmn acting as a mine operator. The Division's <br />jurisdiEtion is to redaim the site to the standards set fordi in the permit, and ensure that the <br />. financial warranty oar achieve this goal. ~ . . <br />Cost Estimate B includes a cost for demolition and disposal of the material on sift: in the: .. <br />amount of 54.6 million. ,The Division believes this scenario should be applied to reflect the <br />required fmautaal warranty for the Lyons site. lldwevcr, in order to approve this plan, some <br />`modification to the mining and reclamation plan may be required. This is discussed in morn <br />detail'below:. . <br />3. 1a order' for mining structures and debris to be disposed of within ttre permit errs, the <br />opet8lor will anti to revise the mining and teclamaton plan. Specifically. the ttpuator wiU <br />coed io revise the peratit to desirnkte a d~osal locatioafor the stntctares and conenste to <br />be boiled on site.:7a addition, tree op4rator will need to commit to a cover de1Nh. and the <br />source foi the cover material (including a covet depth for all foundations to trmaia in <br />place . Without sue ignation, the Division will need to asstrme that all materiel is <br />hauled and dispersed of in an ttppmved landfill off site. The cost for such disposal in an off <br />site laadlill is much higher than rho cost proposed by Banks and Clesso. <br />The Division recently approved such a technical revision'for the Henderson Mine sad Mill <br />(Permit No. M-1977-342) in order to reduce rho sUuCtrual tlemrolitioa cost. Within rho <br />submittal, the operator designated a location for the debris, comnnitted to 3' of overburden <br />material over the disposal site and included information to protect the surface and <br />groundwater by lining the disposal site with an imparmeabic matoriaL Tine technical <br />trvisfon filed by Henderson substantially reduced the cost for demolishing atractutes at the <br />mine. <br />If CEMEX proposes to disposo of rho material within the aflccted aroa of the permit, then a <br />technical revision t0 the permit would be rrquircd. hx additloa, the eompoueats of the <br />rteclamation cost estimate prepared by Banks attd tiesso should also be included is the <br />technical revision. <br />