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~- <br /> <br />George Neserke <br />Coors Energy Company <br />May 4, 1998 <br />Page 2 <br />1) According to information provided as a part of the recent permit amendment <br />to allow for the limited disposal of mine waste rock at the facility the WCHD <br />was informed that B-Pit was approximately 58.7 surface acres. However, in <br />reviewing the DMG Reclamation Cost Summary Form, task no. 6, it appears <br />that B-pit is 43.4 surface acres. This should be clarified as there appears to <br />be a discrepancy. <br />2) A condition of the facility's County permit requires that a minimum of four (4) <br />feet of cover be placed over the ash. Up to this point, I have been unable to <br />ascertain whether the financial assurance with the DMG adequately <br />addresses this item. <br />3) There does not appear to be funds available to make repairs in the cover <br />material following closure. In your March 10, 1998, letter to Glenn Mallory <br />you provide an estimate for post-closure inspections. However, adequate <br />funds should be available to make any necessary repairs in any damaged <br />cover observed during these post-closure care inspections. <br />4) According to the Regulatiohs, permanent surface water diversion structures <br />must remain at the site after closure. We have been unable to determine if <br />these structures are currently in place or if they are in need of construction. <br />This item is in need of clarification. <br />5) The issue concerning financial assurance for the post-closure period should <br />be more formally addressed. According to your March 10, 1998, letter to <br />Glenn Mallory it appears that there is more than adequate funds available to <br />monitor groundwater at the site for the 10-year closure period specified by <br />the DMG. However, the Regulations require that funds be available for up to <br />30 years of post-closure monitoring. We are assuming that your financial <br />assurance with the DMG would be released at the end of this 10 year period. <br />In the event the site is released from its reclamation requirements with the <br />DMG, financial assurance would no longer be in place. We acknowledge that <br />the post-closure care period may be reduced in accordance with Section <br />2.6.2 of the Regulations, however, there should be additional discussion <br />concerning this item. <br />We will resume our review following receipt of the additional information from <br />Byron. We would also appreciate any assistance you can provide us in addressing <br />these items. <br />