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-14- <br />At the time of issuance of the first permanent regulatory program permit, <br />total required bond coverage for that five-year term was set at <br />E2 ,636,800.00. 8y virtue of various revisions to the permit which were <br />approved by the Division subsequent to permit issuance, required bond coverage <br />increased to 53,453,662.00 by the end of the first permit term. During the <br />permit renewal process, reclamation costs for the worst case disturbance <br />occurring during the second permit term (1986-1991} were calculated and <br />resulted in a bond amount of 56,431,188.00. Peabody submitted corporate <br />surety bond No. 9264508 in the required amount on February 20, 1987. <br />Technical Revision IJumber 12 approval on June 5, 1987 required additional <br />bond. Peabody met this requirement by a rider to corporate surety bond <br />No. 9264508 dated June 22, 1987, which increased the original bond amount by <br />544,540.00. Technical Revision JJumber 14 approval on July 22, 1988 also <br />required additional bond. Peabody met this requirement by submitting a letter <br />of credit for 5252,733.00 on July 20, 1986. Thus, total bond held by MLRD for <br />the second permit term equals b6 ,728 ,461.OC. TR-17 involved both an increase <br />in reclamation costs and a decrease in required band because of an earlier <br />error in figuring workmen's compensation costs. Therefore, the total bond now <br />required for the worst case disturbance in the second permit term is <br />56,531,916.00. This amount is 5196,545.00 less than what is now held by <br />MLRD. However, Peabody indicated in TR-17 correspondence that this excess <br />bond amount was to be held by MLRD as a 'bond reserve' for possible future <br />revisions that may involve required bond increases. <br />During the permit renewal process, the Division provided Peabody Coal Company <br />with information regarding procedures for the release of performance bongs <br />covering areas which were mined and subsequently reclaimed during the first <br />permanent program permit term. As indicated in the permittee's Auoust Z9, <br />1986 response, Peabody Coal Company elected not to apply for bond release as <br />part of the permit renewal process. Therefore, bond coverage amounts <br />applicable to all areas mined during Uie first 5-year permit term <br />(53,453,622.00) and prior to the first permit term (51,491,730.00) were <br />retained by the Division until such time that Peabody submits an application <br />for bond release for those areas. The amount retained is in addition to the <br />bond amount which must be retained to cover the worse case disturbance <br />occurring during the second 5-year term. Currently, the Division is holding <br />511,673,859.00 total bond amount for reclamation at the S°neca II Mine. <br />2636E/scg <br />