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Response: The specific Permit text discussion for the Subsidence Control Plan has been reviewed and updated, <br />as appropriate, to reflect current status and conditions. Copies of the revised Permit discussion accompany these <br />responses for replacement in the PAP. <br />25. The Division has recalculated the reclamation cost estimate fore the Williams Fork Mines pursuant to Rifle <br />3.02.2(4). A copy gf the estimate is attached. The new liability for the site was calculated at 53,590,971. <br />The Division currently holds a bond in the amount of S3,552,679. 00. Based on the recalculated reclamation <br />cost estimate, the Williams Fork-Mines are under - bonded by 538,292.00. Please submit a bond rider.for a <br />minimum of $38,292.00 to cover the increased cost of reclamation at the site. <br />Response: MCM has reviewed the CDRMS's updated bond estimate, and accepts the changes in total <br />estimated reclamation costs. We are working with our Corporate Surety to obtain, and will submit a bond rider <br />to our current self-bond to address the noted increase in liability; <br />26 The index sheet for Rifle 3.03 in the permit contains a reference that the reclamation cost estimate is <br />contained in Exhibit 25. While there is a cost estimate in Exhibit 25, it is.1rom the early 1990's A new <br />reclamation cost estimate needs to be included in this exhibit. Please provide the Division with an updated <br />reclamation cost estimate for the Williams Fork Mines. MCM can resubmit a paginated copy of the <br />Division's attached estimate for Exhibit 25 or MCM can supply their own estimate, which will then be <br />reviewed by the Division. <br />Response Given MCM's acceptance of the CDRMS's most recent bond reclamation cost estimate, a paginated <br />copy of this estimate accompanies these responses for replacement in E-d-h bit25. <br />27. A recent problem that has been encountered at many abandoned mine reclamation projects is the presence <br />of asbestos in the structures that must be demolished. The testing for and removal of asbestos is a costly <br />endeavor. The Division has added asbestos testing costs to the Williams Fork Mines reclamation cost <br />estimate. tf MCMcan provide the Division with appropriate documentation that the remaining structures at <br />the Williams Fork Mines do not contain asbestos, the Division will remove this cost from the estimate. <br />MCM can submit this infoi °mation with one of the required revisions. This will give the Division a <br />permitting vehicle to make the adjustment to the cost estimate. <br />Response: MCM has completed asbestos testing, and anNI associated remediation work for all structures that <br />have been recently demolished, but has not conducted this testing for the remaining strictures. At this time it is <br />probably appropriate to retain the additional testing costs in the bond reclamation cost estimate. <br />28. There is a very brief discussion of contemporaneous reclamation on permit page 4.01 -9 This discussion <br />states, in part, that "(a)ll back-filling, grading and topsoil replacement operations will be conducted as <br />contemporaneously as possible. " To date, the Williams Fork- Mines have been idle for 16 yearn and very <br />little reclamation activity has taken place While MCM has stated that mining may commence at the <br />Williams Fork- Mines at a later date; the Division does not have a current mine plan or any definitive plans <br />for the commencement gf mining. The Division believes that, given the extended period of inactivity, final <br />reclamation of the Williams Fork Mines needs to begin this fall. Several questions above deal with the <br />Division's requirement for the initiation of final reclamation at the Williams Fork-Mines. <br />Response Please refer to the previous response to Comment 1. Relative to the issue of contemporaneous <br />reclamation, from both a practical and a regulatoiv perspective, it is recognized that mine facilities will <br />generally remain in place until they are no longer needed for ongoing or future mining and related operations. It <br />is important to note that MCM has taken a pro - active and responsible approach in reclaiming any facilities not <br />needed or suitable for future operations, and has effectively monitored and maintained all other remaining <br />facilities. <br />8 <br />