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+[ <br />^~.. <br /> <br />TR-33 was determined to be incomplete on June 29, 2000. The operator was directed, in the <br />incompleteness notification letter, to submit an evaluation of the worst case consequences of failure, as <br />originally specified. The deadline specified for submittal of the evaluation is July 14, 2000. <br />2. Cessation of Operations Revision Order Issues <br />On Febntary 18, 2000, DMG issued an order to PCC [o submit a revision addressing various items <br />necessitated by the mine closure, by May 18, 2000 (later extended to June 5, 2000). The operator <br />responded with the submittal of TR-32, on June 5. The revision was deemed wmplete on June 13, <br />2000 and is still under review. The most significant issues are summarized below: <br />Item 6. The Division identified concerns with the potential for failure of the upper diversion ditch <br />above refuse azea CRDA-2, and extensive erosion of the refuse pile which would likely result, due to <br />the ditch location and configuration, and configuration of the refuse pile. The Division requested an <br />amended fatal topography for the top of the refuse pile, to ensure Otat debris laden flood waters would <br />not flow across the pile and discharge over the outslope. The revision submittal proposed to construct <br />a new, higher gradient diversion immediately above the refuse area, but did not propose any significant <br />modification of the top of pile topography. <br />Item 9. The Division identified geomorphic concerns with respect to a series of four rock drop <br />sWCtures along a permanent diversion segment of the Coal Creek channel in the vicinity of Refuse <br />Area CRDA-l, and with a concrete mmp road crossing structtue witlt six culverts, immediately <br />upstream of the pemtanem diversion segment DMG concern was due to the observation that the drop <br />stnrctures have accelerated sediment deposition and necessitated frequent cleanout of the channel. <br />During major flow events, flow has come close to breaking out of the channel at rock structure <br />locations, and channel scouring has occurred immediately below several of the drop structures. The <br />Division requested that the rock stntctures be removed, and that the concrete ramp structure be <br />removed during final reclamation, to allow for the channel gradient to adjust as necessary [o <br />accommodate the relocated channel. <br />In the revision submittal, the operator proposed to remove the drop swctures as recommended. The <br />operator did not propose to remove the wncrete ramp crossing, or various other culverts along the haul <br />road segment in Coal Canyon, as they were awaiting comment from BLM, who will have management <br />control of the road following final reclamation/bond release. Subsequently, BLM forwarded <br />comments indipting that they wished all of the culverts and the concrete ramp to remain in place <br />following reclamation. BLM offered their evaluation of the geomorphic consequences of leaving the <br />concrete ramp and culverts in place long term, which differed from DMG's assessment. <br />3. Mid-Term Review <br />The mid-term review date for Roadside Mine is July 3, 2000. That deadline will not be met, but i <br />anticipate issuance of the mid-term by the end of July. As a part of the mid-term review, we will <br />evaluate the adequacy of the bonding insWment (which is apparently in question due to the financial <br />condition of the primary surety, Frontier Insurance Company of New York). We will also evaluate the <br />adequacy of the cost estimate, which was last comprehensively evaluated in January, 1998. The <br />current cost estimate is 52,903,016.00. We hold a 52,603,016.00 corporate surety bond issued by <br />Frontier Insurance Company, and a 5300,000.00 corporate surety bond issued by Utica Mutual <br />Insurance Company of New York. <br />Although I have not really initiated a formal mid-term review, l have developed something of a draft <br />". working list" of potential issues to raise during the midterm. Included on this list are: <br />a) Permanent drainage restoration plan for the south portal facilities area. I think it is questionable <br />whether the current[ plans which entails routing drainage through the conveyor tunnel under I-70 to <br />the river will actually work. ]im Stover has indipted i[ will not work, due to gradient of the <br />