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estate and primes the Lenders' lien on the Machinery and <br />Equipment. 11 U.S.C. ~ 506(c). <br />Third, the Lenders are not entitled to relief from stay, <br />because the proceeds of the sale of the Machinery and <br />Equipment are necessary for an effective reorganization of the <br />parent, Debtor Quaker Coal Company. 11 U.S.C. § 362(d)(2)(B). <br />Fourth, paying the Machinery and Equipment proceeds to <br />the Lender would constitute a de facto abandonment of the <br />contaminated Powderhorn site, because it would strip the <br />Powderhorn estate of practically all of its assets. However, <br />the Debtor cannot abandon the contaminated site because of the <br />imminent and identifiable hazards which the site poses to <br />human health and safety. <br />FACTS AND THE REGULATIONS UNDER WHICH DEBTOR POWDERHORN <br />COAL COMPANY IS REQUIRED TO OPERATE <br />The Debtor Powderhorn's coal mine has a number of <br />portals, above-ground structures, unreclaimed refuse piles, <br />settlement ponds, and large above-ground cuts and excavations. <br />(See, Declaration of David A. Berry, Coal Program Supervisor, <br />Division of Minerals and Geology, Department of Natural <br />Resources, State of Colorado (the "Declaration"), Exhibit A <br />hereto, 9[ 5.1.) One of the portals, the Northwest Intake <br />5 <br />