PERMFILE110572

• Permit No: C1982054
• IBM Index Class Name: Permit File
• Doc Name: MLRB EXHIBITS AGENDA ITEM 10
• Section_Exhibit Name: EXHIBITS A-H
• Media Type: D
• Archive: No

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Findings of the
Colorado Mined Land Reclamation Division
for the
Carbon Junction Mine
Explanation of Findings
Pursuant to Rule 2.08.5(3) of the Regulations of the Colorado Mined Land
keclamation Board for Coal Mining, and the approved state program, the t4ined
Land Reclamation Division or the Board-must maY,e specific-wr.itte n.findinas- .. ___.. __....__
prior to issuance of a permit renewal. These findings are based on
- information made available to the Division that demonstrates whetner the
applicant will be able to operate in compliance with the Colorado Surface Coal
Mininp Reclamation ACt and the Regulations promulgated pursuant-.to_the act. .._
The findings in the following sections required by Rule ?.08.5(3) are listed
in accordance with that Rule. .
This findings document is updated upon permit renewal, which occurs every five
years for most mines. This is the renewal findinps document for the Garbon
Junction Mine. The following findings were reevaluated and updated to reflect
changes which have occurred during the past pe rtnit term.
Findings Repuired by Rule ?.08.5(3)
1. Pursuant to Rule 2.08.5(3)(a)(iv), the Division finds that Pueblo Coal .
Company, Inc. (PCI) has not provided sufficient reclamation bond to
assure the completion of the reclamation plan if the work had to be
performed by the Board, through independent contractors, in the evert of
forfeiture.
in a renewal adepuacy letter dated January 19, 198°, the Division
indicated to PCI that the Division staff had re-evaluated the estimated
test of reclamation for bonding purposes as repaired by statute and tha*.
the revised cost estis~ate exceeded the currently held bond amount. Tne
existing bond amount is ~931,15C,00, vrhiie the Di visier.'s recent worst
case est7mate based on a thorouon 7nvest7oat7on uti7i.ino Current aerial
photovraphs, field measurements, and operator s;,~bmitted macs and reports
was 51,1?5,300.00, an increase of 5194,150. C0 (approximately 2C`;). The
letter indicated that, unless apditional 7nrormation Were submitted by
PCI justifying a loser cost estimate, the bond would need to be increased
accordingly.
PCI has indicated that, due to their bankruptcy status they are unable to
increase the bond amount and do not anticipate being able to do so until
a lawsuit filed by their majority owner is resolved, in a letter of
September 15, 1989, PCI submitted revised reclamation cost calculations.
The calculations were based on the assumption that Pueblo Coal Inc. would
be doing the reclamation with their own employees, thereby reducing wage