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Section V <br />Bonding <br />In February of 1991, Twentymile Coal Company (TCC) received (via TR-12), a <br />variety of surface facilities that previously were under the jurisdiction of <br />Permit No. C-81-071. At that time, it was decided that the transfer would <br />occur and the actual bond liability would remain the same until midterm <br />review, when bond could be recalculated and properly assigned to the <br />appropriate mine. The estimated bond amount for the Transfer was <br />approximately $354,000 and this amount appears to be transferred right out of <br />the C-81-071 permit document. for the purposes of the revision and to <br />expedite approval, this was adequate. However, upon closer examination, it <br />appears that this amount is probably inaccurate, since it was calculated using <br />older methods and without any administrative fees etc. There have also been <br />several minor revisions (including MR Nos. 68, 69, 70, 71, 72) which have <br />increased the liability, but which hard calculation was deferred until <br />midterm. This is a priority issue and needs to be addressed immediately. <br />This should be accomplished in the following manner. <br />1. Submit a bond adjustment application which includes an up-to-date list of <br />facilities and structures associated with the Foidel Creek Mine plus a <br />comprehensive reclamation cost breakdown. Ultimately a revised bond <br />summary will be incorporated into the permit. <br />This process will result in an up dated current bond and will be afresh <br />starting point for any additional bond amendments required from revisions or <br />otherwise. Future revisions should always be submitted with bond calculations <br />attached and in a format which can easily be inserted into the permit. <br />The Division currently has three separate bonds for the TCC on file. One of <br />these was associated with the former Fish Creek Tipple which has now been <br />incorporated into the Foidel Creek permit. The bonds are: <br />No. <br /> <br /> for $1,673,870 - Permit No. C-82-056 <br />The current liability assigned to TCC is $1,673,000.00. This leaves a <br />contingency of $115,670.00. Since Permit No. C-81-036 for the Fish Creek <br />Tipple is no longer active and has been incorporated into the Foidel Creek <br />Mine permit, the bond should be changed to reflect this. This can be done <br />within the context of the above mentioned revision. <br />This concludes the review process. Attention should be given to any deadlines <br />for submitting responses or revisions. <br />AJW/yjb/ern <br />1356E (3/92> <br />