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Reclamation Bond? If there is work planned at the Rock <br />Tunnels not covered by the approved Reclamation Bond what is <br />the authority for this work? Are there documents relating to <br />these costs? If so, please attach a copy of such documents to <br />your responses to these interrogatories or state the <br />circumstances under which these documents may be inspected <br />and /or copied. <br />Response: The work proposed to be accomplished at the <br />Rock Tunnel vicinity is described by component and cost in the <br />Division's Estimated Reclamation Costs by Anticipated Project, <br />dated January 21, 1998, which has been served on the <br />Defendants. <br />Objection: See general objection to the Defendants' <br />definition of the term Reclamation Plan. The definition <br />excludes many portions of the approved permit and, therefore, <br />excludes many reclamation requirements mandated by MCR's <br />permit. Without waiving this objection, the Division's <br />response includes references to reclamation requirements <br />contained in other portions of the approved permit: <br />- Demolition: Technical Revision 07 January 7, 1987, <br />Permit Renewal Application Volume 8, Chapter V, Section C, <br />Volume 2 Chapter II. <br />- Culvert Removal: Volume 8, Chapter V, Section D, Rules <br />4.03, 4.05 <br />- Earth Work: Technical Revision 06, Technical Revision <br />07 <br />- Construct Drainages: Volume 8, Chapter V, Section G. <br />Rule 4.05 <br />- Road Work: Volume 8, Chapter V, Section D. <br />- Revegetation: Volume 8, Chapter V, Section E. <br />As defined by the Defendants in these interrogatories, <br />the term NLRB) Reclamation Bond means the security or pledge <br />posted by Mid - Continent Resources. This document is a Deed of <br />Trust regarding a parcel of land referred to as the Limestone <br />or Rock Dust Plant. This document does not discuss <br />reclamation requirements or costs. Accordingly, as defined by <br />the Defendants, "reclamation bond" does not make reference to <br />any task or cost. <br />21 <br />