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Item 21: Edit. Revised page(s) from TR73 do not match up. 2.05-50 language does not transition to language <br />on page 2.05-50a or 2.05-50.1. Please validate or edit the revised pages. <br />Response: The referenced pages have been reviewed. The revised text from TR10-73 (05/21/10) appears to <br />carry-over from page 2.05-50 through 2.05-50.1 with no lack of continuity and no loss of text. <br />Item 22: Edit. The entire Section of pages 2.05-84.5 thru 2.05-84.10 submitted as TR73 does not correspond <br />with text from previous submittal MR243. Please validate or edit the revised pages. <br />Response: The referenced pages have been reviewed and revised to assure text consistency and continuity. <br />These pages have been revised through a succession of recent revisions, including TR09-66, TR10-73, MR10- <br />243, and MR10-248. Copies of revised pages incorporating all successive text changes accompany these <br />responses for replacement in the PAP. <br />Item 23: Edit. The permit area identified on Map 23 is digitized to be approximately 22,573 acres. This <br />number is in contrast to the 19,940 acres in the Division's system. Please validate or edit any and all maps that <br />may delineate an inaccurate permit boundary. <br />Response: Please refer to the previous response to Item 5. As maps have been revised, the updated permit <br />boundary has been added. We believe that the primary active permit maps (Maps 1, 2, 23, 24, and 29) all show <br />the current permit boundary. <br />Item 24: Rule 3.02.1(7). The TCC bond for permit C-1982-056 is not sufficient to cover reclamation costs. As <br />of November 2, 2010, the Division estimates liability at the Foidel Creek Mine is $9,817,927.00. This amount is <br />sufficient to assure completion of the remaining reclamation work at the site if the work had to be performed by <br />the Division, including the cost of re-establishing vegetation on any revegetated areas, should those areas fail. <br />The permittee currently has on deposit with the Division one Travelers Casualty and Surety Company of <br />America bond in the amount of $9,323,701.00 and one Federal Insurance Company bond in the amount of <br />$439,388. 00for a total of $9,763,089. 00. <br />Based on the updated costs of associated revisions, the direct costs for all reclamation tasks is $7,894,026.00 <br />compared to the direct costs associated with Permit Renewal No. 5 of $7,924,449.21. Indirect costs consist of <br />the Overhead and Profit costs and the Legal, Engineering, and Project Management costs. Overhead and Profit <br />costs consist of Liability Insurance (% of direct cost), Performance Bond (% of direct cost), Job Superintendent <br />(hourly), and Profit (% of direct cost) which make up the Contract Amount (direct cost + Overhead and Profit). <br />The Legal, Engineering, and Project Management Costs consist of Engineering Work (% of contract amount), <br />and Reclamation Management (% of contract amount) for a Total Indirect Cost. The Division's Permit <br />Renewal No. 5 reclamation cost estimate inadvertently estimated the Legal, Engineering and Project <br />Management costs as a percentage of Direct Costs rather than the Contract Amount. Please submit additional <br />bond in the amount of $54,838.00 to cover the total reclamation costs associated with the site. <br />Response: TC added a rider to our existing self-bond in conjunction with MR11-253, which brings the total <br />bonded amount in line with the current calculated total reclamation costs ($9,806,089).