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iv) For permanent stock tank impoundments (as well as sediment ponds proposed <br />for permanent retention) demonstration of compliance with the requirements of <br />4.05.9(73)(a) through (f) wilt need to be provided. <br />2.05.4(21(bl Reclamation Cost Estimate <br />20. Tab 25 of the approved permit application package addresses reclamation cost estimate <br />considerations. No proposed amendments to Tab 25 were included in the PR-4 <br />application, but it is clear that the information will need to be updated to incorporate the <br />mining and reclamation plan changes associated with PR-4. Of particular note are worst <br />case disturbance assumptions, which would be outdated upon approval of PR-4. <br />Currently, Tab 25 narrative projects that worst case disturbance would occur in 2003. <br />Under the PR-4 mine plan revisions, the IIW-South Wadge Pit 2 miles in length would <br />remain open through 2005 to accommodate highwall mining, coincident with the <br />existence of dragline pits in two separate Wolf Creek/Sage Creek Areas. As such, it <br />would appear that 2005 would become the worst case year for purposes of the <br />reclamation cost estimate. <br />Please amend Tab 25 as appropriate to reflect worst case disturbance <br />assumptions as altered by the PR-4 mine plan revisions. Please consider and <br />address the concerns and requests pertaining to worst case backfilling and <br />grading scenarios in Items 27(d), (e), and (f), below, in preparing the Tab 25 <br />amendments. <br />2.05.4(2)(c) Backfilling and Grading <br />21. We have a number of concerns with the backfilling and grading schedule as described on <br />amended pages 5, 5a, Sb of Tab 19, and amended Exhibit 19-1A. <br />a) There is an inconsistency regarding backfilling schedule for the lower "A" Pit 180 day <br />variance areas between amended Exhibit 19-1A and text on amended page 5a. <br />Specifically, the text indicates that the lower "A" Pit variance areas are to be backfilled <br />and graded by the end of 2003, whereas on Exhibit 19-1A, a portion of the "A" Pit <br />immediately adjacent to the "B" Pit area is labeled 2004. The exhibit appears to be in <br />error, and should be amended to specify completion of backfilling and grading in <br />2003. <br />b) The Exhibit 19-1A map legend appears to be misleading in one instance, and needs to <br />be clarified. The concern is with the non-variance area along the southern boundary of <br />the lower "A" Pit area. The legend could be mis-interpreted as indicating that backfilling <br />might not be required until 2005. However, because the 180 day variance did not apply to <br />the subject area, backfilling and grading is to be completed in 2003. Please add a <br />notation to the map to specify completion of backfilling and grading in 2003. <br />