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such requirements. <br />c. Diane Delaney to immediately complete the sealing <br />of the adit /rock tunnel; immediately reclaim Mine 1, <br />2, 3, 4, and 5 portal areas, including portal seal- <br />ing, structural demolition, backfilling and grading, <br />revegetation, and installation of sediment controls; <br />complete reclamation of the Coal Basin Mine pursuant <br />to the reclamation plan, the provisions of CSCMRA, <br />the regulations promulgated thereunder, and the Final <br />Reclamation Schedule specified in the Board order <br />dated May 22, 1991; maintain the site in compliance <br />with all applicable statutory, regulatory, and permit <br />requirements; and abate any violation of such <br />requirements. <br />d. Minerals to immediately complete the sealing of <br />the adit /rock tunnel; immediately reclaim Mine 1, 2, <br />3, 4 and 5 portal areas, including portal sealing, <br />structural demolition, backfilling and grading, <br />revegetation, and installation of sediment controls; <br />complete reclamation of the Coal Basin pursuant to <br />the reclamation plan, the provisions of CSCMRA, the <br />regulations promulgated thereunder, and the Final <br />Reclamation Schedule specified in the Board order <br />dated May 22, 1991; maintain the site in compliance <br />with all applicable statutory, regulatory, and permit <br />requirements; and abate any violation of such <br />requirements. <br />35. In the alternative, the Division respectfully requests <br />that the Court entar a money judgment for the cost of reclamation <br />in favor of the Division and against John A. Reeves, Robert <br />Delaney, Diane Delaney, and Minerals, jointly and severally; and <br />such other relief, including costs and attorneys' fees, as the <br />Court deems appropriate. <br />RESPECTFULLY submitted this d of <br />GALE A. NORTON <br />Attorney General <br />TIMOTHY M. TYMKOVICH <br />Solicitor General <br />-6- <br />RAYMOND T. SLAUGHTER <br />Chief Deputy Attorney General <br />