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TR-52 included such changes as Permit text, revised culvert designs, revised ditch designs, replacement of a clean water plunge pool with a cleanwater ditch downdrain, revised orientation of the concrete pad and fan structure, revised disturbance and topsoil calculations, revised post mine topography and cross-sections, revised reclamation material mass balance, revised Sediment Pond F design, revised Mine Disturbance Area Table, etc. Clearly, TR-52 was the most efficient and effective mechanism to incorporate the final Hubbard Fansite as-built configuration into the PAP. While TR-52 wvered a variety of issues related to the facility, no change in reclamation liability was determined to be applicable. Had an increase in reclamation liability been determined, Oxbow has bond contingency to cover the difference. TR-51 -Hubbard Fansite Boreholes The mechanism for permitting of the boreholes at the Hubbard Fansite was TR-51. Completion of the boreholes did not include additional surface disturbance beyond that already existing for the Fansite facility. While the TR-51 application also requested DMG consideration of additional reclamation liability, the Division's final TR approval did not. The application text and Drawing 2.05-El-HFS "Facility Designs Hubbard Creek Fansite" acknowledged the potential for more than one attempt to complete the B seam borehole. In fact, the B seam borehole took three attempts. The first two attempted boreholes failed to reach B seam mining voids and will be sealed with concrete as soon as a concrete tnrck can safely reach the site. The third B seam attempt was successful and the B seam mining void was encountered at 336'. The D seam water hole (only 53 feet deep) was readily completed. Due to the potential need for another utility borehole for possible methane drainage, electrical, au or water, Oxbow had the drill rig simply move over and complete a second D seam borehole while on site using the existing mud pit. See Photograph #2 for a view of the final borehole locations. In summary, while three potential drilled boreholes were predicted in TR-51, a total of five boreholes were eventually drilled, with three boreholes to be used and two boreholes to be filled with concrete. Similar to the experience with the overall Fansite construction, we anticipated that once the boreholes were completed, we would later provide a permit revision to efficiently include the as- built information into the PAP. The as-built information would include accurate completed borehole locations, completion diagrams, revised maps etc. During the January 18, 2006 CDMG inspection, the Hubbard Fansite was inspected. After describing the configuration of the completed boreholes and status of unsuccessful boreholes, I noted that the information for the as-built borehole configuration permit revision was being prepared as we spoke. As soon as the borehole completion diagrams and maps were completed, the revision would be promptly submitted. I noted that the submittal of the as-built information was an exercise similar to that accomplished by submittal of TR- 52 for the overall Hubbard Fansite facility. Oxbow had made no attempt to hide our intentions or shirk our responsibility to • Page 2