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I1 than undisturbed areas, although not of the magnitude of the analysis. [The Division finds that all factors less cover of the Universal Soil Loss Equation (USLE) equation used are similar. The more protective "C" or cover factor of the reclaimed areas results in the finding.] Remaining Reclamation Work The Division determined the remaining reclamation work required at the site, and developed a cost estimate to accomplish this work by a third party contractor. The estimated cost to complete the remaining required reclamation was, as of July 13, 1998, $2,334,441, and includes, as a separate line item, monies (financial assurance) for water quality monitoring for ten years. Water Quality By review of the Annual Hydrologic Reports submitted by CEC, the Division determined that no surface or underground water pollution had occurred or was occurring. There had been no discharge of surface water from the site (sedimentation ponds) at the site. Samples from monitoring wells indicated no impact to the quality of ground water about the site. In addition, from geological, geotechnical, topographic, climate and operational information found within the Permit, the Division determined that the probability of future occurrence of pollution is low (requiring, at this time, no estimated cost for abatement). IV. CONCLUSIONS Phase I Based upon a review of the mine Permit, the Bond Release Application, and previous and recent site inspections, the Division finds that CEC has backfilled, graded and established drainage on 179 acres of 413 disturbed at the Keenesburg Mine in accordance with the approved reclamation plan. Areas fo which Phase I Bond Release has been applied meet the criteria of Rule 3.03.1(2)(a). Phase II The Division finds that topsoil was replaced over the 111 acres of the Application in accordance with the approved reclamation plan. The Division finds that the 1985 reclaimed parcel fails to meet the cover standard when the vegetation data collected during August 1996 is used as a basis for evaluation. However, investigation of previous vegetation monitoring data collected in 1994 and 1995 finds that the 1985 reclaimed parcel met the cover standard in both 1994 and 1995. The 1994 and 1995 vegetation sampling data was not submitted in the Application but is available in the 1994 and 1995 Annual Reclamation Reports. The 1985 parcel meets the requirements of Rule 3.03.1(2)(b). 11 August 93