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Rule 3.0 — Performance Bond Requirements <br />25. The Division has recalculated the reclamation cost estimate for the Williams Fork Mines <br />pursuant to Rule 3.02.2(4). A copy of the estimate is attached. The new liability for the <br />site was calculated at $3,590,971. The Division currently holds a bond in the amount of <br />$3,552,679.00. Based on the recalculated reclamation cost estimate, the Williams Fork <br />Mines are under - bonded by $38,292.00. Please submit a bond rider for a minimum of <br />$38,292.00 to cover the increased cost of reclamation at the site. <br />26. The index sheet for Rule 3.03 in the permit contains a reference that the reclamation cost <br />estimate is contained in Exhibit 25. While there is a cost estimate in Exhibit 25, it is from <br />the early 1990's. A new reclamation cost estimate needs to be included in this exhibit. <br />Please provide the Division with an updated reclamation cost estimate for the <br />Williams Fork Mines. MCM can resubmit a paginated copy of the Division's <br />attached estimate for Exhibit 25 or MCM can supply their own estimate, which will <br />then be reviewed by the Division. <br />27. A recent problem that has been encountered at many abandoned mine reclamation <br />projects is the presence of asbestos in the structures that must be demolished. The testing <br />for and removal of asbestos is a costly endeavor. The Division has added asbestos testing <br />costs to the Williams Fork Mines reclamation cost estimate. If MCM can provide the <br />Division with appropriate documentation that the remaining structures at the Williams <br />Fork Mines do not contain asbestos, the Division will remove this cost from the estimate. <br />MCM can submit this information with one of the required revisions. This will give the <br />Division a permitting vehicle to make the adjustment to the cost estimate. <br />Rule 4.13 — Contemporaneous Reclamation <br />28. There is a very brief discussion of contemporaneous reclamation on permit page 4.01 -9. <br />This discussion states, in part, that "(a)11 backfilling, grading and topsoil replacement <br />operations will be conducted as contemporaneously as possible." To date, the Williams <br />Fork Mines have been idle for 16 years and very little reclamation activity has taken <br />place. While MCM has stated that mining may commence at the Williams Fork Mines at <br />a later date, the Division does not have a current mine plan or any definitive plans for the <br />commencement of mining. The Division believes that, given the extended period of <br />inactivity, final reclamation of the Williams Fork Mines needs to begin this fall. Several <br />questions above deal with the Division's requirement for the initiation of final <br />reclamation at the Williams Fork Mines. <br />Rule 4.24 — Operations on Alluvial Valley Floors <br />29. The discussion of mining under the alluvial valley floors within the Williams Fork <br />Mines' permit area, beginning on permit page 4.01 -13, only includes information for the <br />first permit term. The Williams Fork Mines is currently in its fifth permit term. Please <br />update the discussion of mining activities under the Yampa River (Big Bottom) and <br />Williams Fork River Alluvial Valley Floors for all permit terms up to and including <br />Williams Fork Mines C -1981 -044 <br />2011 Midterm Review (MT -06) -12- 28 June 2011 <br />