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FROM:natural TO: 1 303 2410336 MAR 20, 1995 1:23PM #942 P.03 <br /> operated the entire mine or the operations may have been <br /> conducted differently from in the past. These factors <br /> potentially would contribute to a change in the estimated cost of <br /> reclamation. <br /> (b) Mid-Continent continued to provide revisions to <br /> the reclamation plan as recently as mid-1994 . The intent of the <br /> revisions was to provide a level of detail to the reclamation <br /> plan which is not present in the permit document. Revisions to <br /> the reclamation plan potentially change the estimated cost of <br /> reclamation. <br /> (c) After it was determined that the bankruptcy funds <br /> were public monies, the Division began preparing Invitations For <br /> Sid and other activities, which gave the Division a better <br /> understanding of what the cost of reclamation would be for the <br /> site. <br /> (d) As stated below, the Division had to add details <br /> and other reclamation requirements to the plan in order to ensure <br /> reclamation to applicable standards. <br /> (e) Reclamation is an on-going process. Until <br /> reclamation has been satisfactorily accomplished, conditions at <br /> the site continue to change, requiring continuing changes to <br /> reclamation cost estimates. <br /> These factors contributed to not completing an updated cost <br /> estimate until recently. <br /> 6 . The estimated cost of performing reclamation at the <br /> mine site has increased for a number of reasons. For example, in <br /> some instances, the cost of performing specific reclamation tasks <br /> has increased because a greater degree of detail has been applied <br /> to the required reclamation tasks than that which had previously <br /> been applied, It is almost impossible to determine whether <br /> complete and adequate reclamation was provided for at some areas <br /> disturbed by mining operations due to the vague description of <br /> the reclamation tasks contained in the previous estimate. In <br /> other instances, reclamation tasks which are not addressed in the <br /> permit are now included in the cost estimate because such tasks <br /> are required to comply with applicable regulatory requirements <br /> and standards. <br /> 7. A greater degree of detail was applied to the most <br /> recent cost estimate than that which had previously been applied <br /> -2- <br />