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Adequacy July 27.doc 2 7/27/2006 <br />area due to a sale or permitting actions, please provide that explanation as well, to maintain accurate <br />tracking of permitted and disturbed acres. <br />4. Rule 2.03.4 requires identification of interests and officers. Coors Energy Company's pazent <br />company, Coors Brewing Company, merged with Molson Brewing in early 2006. Please provide <br />updated pages to include in the permit for ownership and officers information. Please include officers' <br />end dates and beginning dates, for positions that underwent changes in personnel. <br />5. Please review section 2.03.4(7) of the permit and provide and updates to surface and mineral <br />ownership as necessary. <br />6. If any surface or mineral ownership changes have occurred since permit sections 2.03.4(6) and (7) <br />were last updated (August 2004), please update permit section 2.03.6 as well to reflect legal right of <br />entry information. <br />7. Permit section 2.03.12, permit page 33, provides information regazding the location of legal notice <br />publications. Since this page was last updated, the name of the newspaper used for publication of <br />legal notices for the Keenesburg Mine has changed to The South Weld Sun. Please update this page to <br />reflect the correct name of the newspaper used for publication of legal notices. <br />8. Rule 4.14 backfill and grading. The Division's RN4 findings document states that "Flyash disposal is <br />anticipated to last to 2010." Permit page 117 states that CEC has been granted a variance on <br />conducting contemporaneous reclamation on B-pit until March 2009. Based upon on-the-ground <br />observation of ash fill progress in the B-pit, and discussions with mine personnel during inspections, <br />the projected date for completion of ash disposal needs to be revised. Please provide an updated <br />projection for completion of fill for B-pit and revise permit pages that discuss the reclamation time <br />frame as well. <br />9. In accordance with Rule 3.02.2(6), the Division has reviewed the reclamation cost estimate for the <br />Keenesburg Mine. This review entailed updating costs for the 2004 during the midterm review <br />reclamation cost estimate, removing costs that were approved for phase I and phase II bond release <br />during the approval of SL2 and SL3, and addition of costs associated with any revisions approved <br />since the 2004 midterm. Review of reclamation tasks included in the estimate was conducted to <br />assure that all reclamation tasks remaining on the mine site are included in the estimate. Tasks that <br />have been completed on the mine site, but not yet approved for bond release, remain in the <br />reclamation cost estimate. <br />The Division used a computer program known as CIRCES to conduct the reclamation cost estimate. <br />CIRCES utilizes cost data from the Cost Reference Guide (CRG), Colorado Department of <br />Transportation, RS. Means Environmental Remediation Cost Data, R.S. Means Site Work and <br />Landscape Cost Data, and Caterpillaz Performance Handbook. Cost updates to the CIRCES program <br />were made in May and July 2006, and reflect as up-to-date labor and equipment costs as available to <br />the Division. <br />The Division's July 2006 reclamation cost estimate for the Keenesburg Mine totaled $2,327,437.00. <br />The reclamation cost liability for the mine prior to the Permit Renewal 5 (RNS) review was <br />