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-56- The Division has approved Phase I of the proposed waste structure. Phase I contains sufficient waste disposal area to accommodate the mines' waste production during the next five to eight years. However, Phases II & III of the proposed structure will have to be approved prior to approval of future permit periods. There are several specific aspects of the conceptual plans for Phases II and III which mAy require significant effort to resolve. The applicant proposes a subdrain to accommodate the surface flow of the ephemeral channel separating the East and West Ridges. This subdrain will require considerable geotechnical and hydrogeological justification and specific final engineered design. In addition, stability analyses for Phases II and III will be required prior to approval of either of these facilities in later permit terms. CWI understands that mining can proceed only as long as a waste disposal site with capacity is available and permitted by the Division. Reclamation of the waste pile will be concurrent with its construction. As outlined in Sections 2.05.4 (2)(a) and (e ), a 3.75-foot non-toxic material/0.15-foot topsoil berm is constructed on the outslopes after completion of each lift. The outslopes are fertilized and seeded each fall. The operation is in compliance with this section. XIX. BONDING (2.05.4 (2) (b) ) The estimated cost for reclaiming the entire Orchard Yalley Mine site by independent contractors has been calculated by the applicant. This cost estimate includes such items as building removal, sealing of portals and underground openings, backfilling and grading, topsoil placement, drainage control, and revegetation. The cost for reclaiming all of the facilities at the Orchard Valley mine operation have been calculated to be ;1,959,697.00. The proposed operation is in compliance. XX. SEALING OF DRILLED HOLES AND UNDERGROUND OPENINGS (2.05,4 Narrative describing portal entry closure and drill hole abandonment is found on pages 76-78 of Section 2.05. Shaft seals are diagrammed on Figure 2.05.6 of Volume 6A. All concerns regarding sealing of drilled holes and underground openings have been resolved, and the proposed operation is in compliance. XXI. SUBSIDENCE (2.05.6(6), 4.20) Subsidence is discussed on pages 136-165 of Section 2.05 in Volume 1. Subsidence appendices are found in Yolume 3. Baseline documentation of surface water features, potentially impacted by subsidence are located in Volume 4. Annual hydrologic reports and subsidence reports have been produced annually since 1982, and exist as stand-alone volumes.