2008-05-18_REVISION - C1992080

• Permit No: C1992080
• IBM Index Class Name: REVISION
• Doc Date: 5/18/2008
• Doc Name: Email Regarding Reclamation Bond Recalculation
• From: Savage & Savage
• To: DRMS
• Type & Sequence: RN3
• Media Type: D
• Archive: No

Kaldenbach, Tom
From: [e-mail]
Sent: Monday, August 18, 2008 8:19 AM
To: Kaldenbach, Tom
Subject: RE: Carbon Junction Renewal Reclamation Bond Recalculation
Tom,
I am out of the office this week but would like to set up a meeting with you and Dan next
week (rues, Wed, or Thurs works for me). Would you e-mail me back with the day and time.
Thanks,
Mike Savage
-----Original Message-----
>From: "Kaldenbach, Tom" <[e-mail]>
>Sent: Aug 14, 2008 12:14 PM
>To: [e-mail]
>Subject: RE: Carbon Junction Renewal Reclamation Bond Recalculation
>Mike,
>It would be best to meet and discuss the questions. Give me or Dan a
>call.
>Tom
>-----Original Message-----
>From: [e-mail]
>[mailto:[e-mail]]
>Sent: Thursday, August 14, 2008 11:13 AM
>To: Kaldenbach, Tom
>Cc: [e-mail]
>Subject: Carbon Junction Renewal Reclamation Bond Recalculation
>Tom,
>I started reviewing the revised reclamation bond calculation for the
>Carbon Junction Mine renewal and and your observations and need a
>couple clarifications.
>Does the Division now agree that the topsoil in Topsoil Stockpiles #4
>and #7 is excess, that the stockpiles may remain in place and
>re-distribution from these piles will not be required to satisfy the
>reclamation plan?
>If Oakridge Energy submits a technical revision addressing these
>topsoil stockpiles, what exactly would be needed to be addressed in the
>permit document text, and what documentation would be required to
>remove the pertinent tasks (38,and portions of 39 and 40) in the
>reclamation cost estimate? Would the revision be considered a "bond adjustment"
>revision, not subject to the requirements of a bond release?
>In such a technical revision addressing "bond adjustment", would the
>Division consider revising the bond calculations for the tasks that
>have been completed, for example, all the final reclamation work done
>in 2006? It is still our reading of the statute and regs that the
>Division has no obligation to perform work that has already been
>successfully conducted (and liability released under Phase I),
>therefore, there is no reason for the Division to hold reclamation bond monies for such
work.
>We believe that Division is not recognizing the difference between
>reclamation bonding and reclamation liability. Is this a topic that
>would be best addressed by the Board in a Request for Declaratory Order?
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