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FROM:natural TO: 1 303 2410336 MAR 20, 1995 1:23PM #942 P.04 <br /> because the Division has become increasingly more knowledgeable <br /> about the individual components of reclamation tasks required at <br /> the site. In addition, since Mid-Continent Resources failed to <br /> complete reclamation of the site as ordered by the Mined Land <br /> Reclamation Board, the Division must now ensure such reclamation. <br /> in order to do so, specificity of tasks had to be determined. <br /> 8 . There are certain items included in the new reclamation <br /> cost estimate which are not specified or contemplated within the <br /> context of the permit document but which are required to meet <br /> applicable regulatory requirements and standards. For example, <br /> earlier cost estimates apparently did not take into account the <br /> reclamation obligations incurred by Mid-Continent Resources at <br /> some mine facilities. The Reclamation Cost Summary Form <br /> contained in the 1991 cost estimate does not contain line item <br /> accounting of reclamation costs for all of these facilities. In <br /> addition, there are other tasks that are now included in the <br /> estimate which were not included in the earlier estimates, such <br /> as construction of a new channel for Dutch Creek in the vicinity <br /> of the facilities area, construction of diversion ditches at the <br /> Rock Tunnel Waste Rock Disposal Facility and at the Old Refuse <br /> Area. All of these items are necessary to complete reclamation <br /> if the site is to meet applicable regulatory requirements and <br /> standards . <br /> 9 . The Division' s current reclamation cost estimate <br /> includes costs for all reclamation tasks which need to be <br /> undertaken at the mine site. These include costs for structural <br /> demolition, foundation removal, backfilling and grading, <br /> hydrologic control work and revegetation of disturbed areas. <br /> 10 . Mid-Continent Resources has accomplished some <br /> reclamation tasks included in the cost estimate at the mine site. <br /> These accomplishments include backfilling and grading of the No. <br /> 5 Mine entry benches, backfilling of the Nos. 1, 2, 3, 5 Mine entry <br /> portals, ripping of the No. 5 Mine benches, topsoil application <br /> at the No. 5 Mine, sealing of all underground openings, and <br /> partial structural demolition of the buildings and associated <br /> mine facilities. The value of the work accomplished by Mid- <br /> Continent has not been taken into account in the current cost <br /> estimate. The Division is in the process of determining the <br /> value of such work. Even with the performance of this work, the <br /> cost of completing reclamation will be more than $3 million. <br /> -3- <br />