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Rule 3.02.2(4) Reclamation Cost Estimate <br />A revised, as of September 1, 1999, cost estimate for remaining reclamation work was <br />$2,308,167. A 2004 Midterm Review Cost Estimate has been developed by the Division and <br />totals $2,761,007. See Section VI below. <br />Rule 4.07 Sealing of Drilled Holes et al <br />In compliance. All holes not required for the current monitoring program or reclamation <br />operations have been mined through or sealed (PAP, page 114b). To better prepare for eventual <br />Phase III Bond Release, the applicant is asked to expand the PAP with more information, <br />including the fire protection well, water supply wells, and to include the remaining drill logs in <br />the PAP. With regard to Rule 4.05.13(1)(e), well completion reports aze the most efficient way of <br />demonstrating compliance with this rule. Well abandonment reports are required by Rule <br />4.07.3(3). Reports have been provided to the Division, but not all have been made a part of the <br />PAP. A well completion report for AMW-2 was found in the PAP on pages 57c through 57f. <br />Well completion reports for AMW-1, SMW-2, DH 122, and FPWl were found collated with the <br />Division of Minerals and Geology (Division) copy of the PAP. The applicant is asked to <br />incorporate the well completion reports for AMW-l, SMW-2, DH 122, FPWl, DH 96 and the <br />water supply well (Colorado Division of Water Resources Permit 48289-F) into the PAP to <br />demonstrate compliance with Rule 4.05.13(1)(e), assist in the development and maintenance of <br />reclamation cost estimates (Rule 3.02.2), and to demonstration compliance with Rules <br />4.05.13(1)(e)(ii) and 4.07. Compliance with the later needs to be validated by the time Phase III <br />Bond Release is approved. FPW 1 and two (one abandoned) water supply wells have been <br />registered (see page 4 Appendix D-lA, of the PAP) with the Colorado Division of Water <br />Resources (Permits 118331, 24650-F, and 48289-F). An abandonment report has been filed with <br />Colorado Division of Water Resources for the abandoned water supply well (Permit 24650-F). <br />Rule 4.17 Air Resource Protection <br />In compliance. See page 124 of the PAP. Special actions are taken with regard to the disposal of <br />flyash and water sprays are used to settle fugitive dust. Air emission permits have been allowed <br />to expire. That APEN procedures are now in effect is an item of interest identified during this <br />review. <br />Rule 4.22 Concurrent Surface and Underground Mining <br />In compliance by exception. There is no underground mining at the site. <br />Rule 4.26 Mountaintop Removal <br />In compliance by exception. There are no mountaintop removal operations at the site. <br />Page6 of 7 Pages <br />