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first bond release field inspection. The Division had approved Technical Revision No. 42, in which BRL
<br />had submitted a slope stability study that showed that the backfilled slope at the West Mine had a factor
<br />of safety in excess of the required 1.3. Also, BRL increased the size of the lower portion at the West Mine
<br />where future excavation will be needed. The Division noted that BRL constructed a concrete cap over the
<br />backfilled West Mine fan shaft. BRL also agreed to work with BLM to resolve the issue of the rock scarp
<br />along the livestock trail. There were still several outstanding issues, however. One issue concerned the
<br />West Ridge waste pile. The Division informed BRL that the West Ridge waste pile would need to be
<br />completely reclaimed before any bond money for the waste pile could be returned.
<br />On November 24, 2003, the Division received the OSM inspection report, dated November 10, 2003, that
<br />dealt with the June 10, 2003 bond release field inspection. The inspection report noted the sites visited
<br />during the bond release inspection.
<br />The BLM sent a letter to the Division, dated December 16, 2003 and received at the Division on
<br />December 19, 2003, in which the road and livestock trail situation at the West Mine was clarified. BLM
<br />verified that the road that leads from the Steven's Gulch road to the West Mine entrance, called the
<br />Blough Road, is to be left in place. Also, BLM stated that the lower East Roatcap Creek Road was not to
<br />be reconnected to the Blough Road although the re-established road segment across the backfilled area
<br />was to remain for the sake of slope stability. BLM also stated that the livestock trail should be left as is,
<br />except that the trail is to be reconnected to the lower East Roatcap Creek road afrer the two sediment
<br />ponds are removed in the future. Finally, the BLM listed several items that they wanted done for future
<br />reclamation, noting that they were outside of the current bond release application.
<br />On December 22, 2003, the Division received an adequacy review response letter dated December 17,
<br />2003 from BRL. In that letter, BRL stated that MSHA does not issue approval letters relating to the
<br />sealing of portals, adits or shafts. The Division has observed enough phases of the sealing procedures
<br />during normal monthly inspections to conclude that the mine opening seals are in compliance. Among
<br />other items in their response letter, BRL supplied revised maps that reflected the wishes of the BLM
<br />concerning roads and trails at the West Mine. Also, BRL estimated that 10,000 cubic yards of soil
<br />material are left to be excavated in the future at the lower portion of the West Mine backfilled and graded
<br />area.
<br />The Division sent its third adequacy review letter, dated January 9, 2004. A summary of the resolution
<br />status of the issues was presented. Most of the issues had been resolved. The Division did request that
<br />BRL insert the BLM letter dated December 16, 2003 and revised text and maps into the permit
<br />application through a revision. Included in that review letter was the Division's estimate of the amount of
<br />bond money that could be returned to BRL under the partial Phase One bond release. The Division's
<br />estimate was $1,121,976.OQ which was lower than BRL's original request of $1,200,000.00.
<br />BRL responded to two adequacy review issues in a letter dated January 20, 2004 and received at the
<br />Division on January 22, 2004. First, the West Mine as-built contour map was revised to include a note
<br />that the livestock trail would be connected to the lower East Roatcap Creek road afrer the two sediment
<br />ponds are removed. BRL also stated that they would submit a technical revision to revise the permit text
<br />and maps to conform to the wishes of the BLM for the roads and livestock trail at the West Mine. On
<br />January 20, 2004, under separate cover, BRL submitted Technical Revision No. 43 to address the West
<br />Mine road and trail issues. The revision was approved on February 20, 2004.
<br />BRL presented suggested modifications to the Division's estimated bond release amount in a letter dated
<br />January 29, 2004 and received at [he Division on February 2, 2004. The Division reviewed BRL's
<br />suggestions and revised the bond release amount in its fourth adequacy review letter dated February 20,
<br />2004. BRL informed the Division, in a letter dated March 5, 2004, that this amount was acceptable.
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