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Ross Gubka, WFC <br />C- 1981 -008 f RN -06 PAR <br />April 12, 2013 <br />Page 2 of 2 <br />Objections to RN -06 were received from JoEllen Turner on December 21 (via facsimile) and <br />December 26 (facsimile by way of OSM). On January 3 we received an objection from the <br />Morgans' attorney. These items were transmitted to Western Fuels on January 29, 2013. None <br />of these objections included a request for an informal conference. <br />On February 7, 2013, (19 days after the public comment period had closed), the Division <br />received a letter from Mary Jean Woods. That letter is attached to this review, for your <br />information. <br />Adequacy Comments <br />The Division has completed a review of the permit for RN -06. Items which will require your <br />attention and response are described below. <br />Section 2.03 — Legal, Financial, Compliance and Related Information <br />1. A check of the Applicant Violator System (AVS) was completed on March 29, 2013. <br />Certain discrepancies were noted regarding ownership and control of Tri -State <br />Generation & Transmission Assoc. and Western Fuels - Colorado, LLC, as detailed in the <br />attached document. Please address these items, and submit any revised permit pages, as <br />appropriate. <br />Section 3.02 — Performance Bond Requirements <br />2. The Reclamation Cost Estimate (RCE) for the New Horizon Mine was last updated in <br />2009 for the issuance of Permit Renewal No. 5 (RN -05) and Surety Release No. 11 (SL- <br />11). The Division has conducted a review of the RCE, to include modifications made to <br />the reclamation plan as approved under PR -06. These changes, together with updated <br />equipment costs, have resulted in an increase to the reclamation bond required. The <br />current surety, required and actual, is $5,042,302.00. For RN -06, the estimate has been <br />increased to $5,702,700.81. A copy of the estimate is provided with this letter, for your <br />review. The amount of the required surety increase will be $660,398.81. The increased <br />bond amount must be posted prior to issuance of the renewal. <br />This completes the Preliminary Adequacy Review for Permit Renewal No. 6 at the New Horizon <br />Mine. Please contact me with any questions that may arise as you prepare the response package. <br />Sincerely, <br />Marcia L. Talvitie, P.E. <br />Environmental Protection Specialist <br />Enclosures — (3) <br />