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the reclamation cost estimate would be appropriately adjusted to Yeflect structural <br />removal and (in the case of the South Portals) structural installation. However, <br />Phase 1 release would not be granted for the disturbed areas as a whole, because of <br />remaining structural and/or backfilling work to be conducted. Projected cost for the <br />remaining work would be retained in the reclamation cost estimate. <br />At CRDA-1, most of the pile has been fully reclaimed and permanent drainage <br />structures are in place, but a section of temporary road has been left open for future <br />disposal of coaly material. At the RSRDA, the pile slopes have been reclaimed and <br />permanent drainage diversions installed, but the final reclamation of the top of the <br />pile has not been completed. Given the extent of reclamation work completed on <br />these piles, we anticipated that our decision will be to grant Phase 1 release for the <br />portions of each pile where reclamation has been completed, with the temporary <br />road on CRDA-1 and the top of RSRDA specifically excepted. At the North Portal <br />area, backfilling and grading has been largely completed, but a number of permanent <br />ephemeral drainage channels are not yet constructed, and are not to be constructed <br />until removal of the temporary upper diversion and sediment control structures is <br />approved. Phase 1 release will be granted for the backfilling and grading <br />successfully completed at the North Portal Area, but liability will not be released for <br />the permanent ephemeral channels, and the cost for installation of the channels will <br />be incorporated into the Division's reclamation liability cost estimate. We further <br />note that, in accordance with permit commitment in Tab 14 of the application <br />package, the permanent drainage channels will not be eligible for final Phase 3 bond <br />release for a minimum of 3 years following completion of construction. <br />4 <br />