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TR-33 waz determined to be incomplete on June 29, 2000. The operator was directed, in the incompleteness notification letter, to submit an evaluation of the worst case consequences of failure, az originally specified. The deadline specified for submittal of the evaluation is July 14, 2000. 2. Cessation of Operations Revision Order Issues On February 18, 2000, DMG issued an order to PCC to submit a revision addressing various items necessitated by the mine closure, by May I8, 2000 (later extended [o June 5, 2000). The operator responded with the submittal of TR-32, on June 5. The revision was deemed complete on June 13, 2000 and is still under review. The most significant issues are surmnarized below: Item 6. The Division identified concerns with the potential for (allure of tite upper diversion ditch above refuse area CRDA-2, and extensive erosion of the refuse pile which would likely result, due to the ditch location and configuration, and configuration of the refuse pile. The Division requested an amended fatal topography for the top of the refuse pile, to ensure that debris laden flood waters would not flow across the pile and discharge over the outslope. The revision submittal proposed to construct a new, higher gradient diversion immediately above the refuse area, but did not propose any significant modification of the top of pile topography. Item 9. The Division identified geomorphic concerns with respect to a series of four rock drop structures along a permanent diversion segment of the Coal Creek channel in the vicinity of Refuse Area CRDA-1, and with a concrete ramp road crossing sWCture vvitlt six culverts, immediately upstream of the pennanent diversion segment. DMG concern u•as due to the observation Hutt the drop swctures have accelerated sediment deposition and necessitated frequent cleanout of the channel. During major flow events, flow has come close to breaking out of the channel at rock sWC[ure locations, and channel scouring has occurred immediately below several of the drop swctures. The Division requested that the rock swc[ures be removed, and that the concrete ramp structure be removed during final reclamation, to allow for the channel gradient to adjust as necessary to accommodate the relocated channel. In the revision submittal, tite operator proposed to remove the drop swctmes as recommended. The operator did no[ propose to remove the concrete ramp crossing, or various other culverts along the haul road segment in Coal Canyon, as they were awaiting comment from BLM, vaho will have nuutagement control of the road following fia'11 reclamation/bond release. Subsequently, BLM forwarded comments indicating Utat they wished all of the culverts and the concrete ramp to remain in place following reclamation. BLM offered Uteir evaluation of the geontorpltic consequences of leaving tite concrete ramp and tvlverts in place long term, which differed from DMG's assessment. 3. Mid-Term Review The mid-term review date Cor Roadside Mine is July 3, 2000. That deadline will not be rnet, but 1 anticipate issuance of the mid-term by the end of July. As a part of the mid-term review, vve will evaluate the adequacy of the bonding instrument (which is apparently in question due to tite financial condition of the primary surety, Frontier Insurance Company of New York). We will also evaluate the adequacy of the cost estimate, which was last contpreltensivelyevtiluated in January, 1998. The current cost estimate is $2,903,016.00. We hold a $2,603,016.00 corporate surety bond issued by Frontier Insurance Company, and a 5300,000.00 corporate surety bond issued by Utica Mutual Instuattce Company of New York. Although 1 have not really initiated a formal mid-tenn review, I have developed something of a draft "working list" of potential issues to raise during the mid-term. Included on this list are a) Permanent drainage restoration plan for the south portal facilities area. I think it is questionable whether the current plan, which entails routing drainage through the conveyor tunnel under I-70 to the river will actually work. Jim Stover has indicated it will not work, due to gradient of the