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as reclamation of the Williams Fork Strip Pit and the Utah Track for example. It is recommended this <br />information be retained in this Exhibit or replaced with an updated reclamation cost estimate for the <br />entire site provided by MCM. This exhibit should also contain the most recent reclamation cost <br />estimate once it is finalized along with supporting material. Please clarify or otherwise indicate how <br />Exhibit 25 will be organized. <br />v) The Division will need to update Task 001 based on the items discussed above. For each structure or <br />facility to be reclaimed, the Division will need accurate dimensions of each of the structures, <br />information on what the structures are made of (metal, wood etc.), structure pad dimensions and <br />depths, dimensions /length/type of footers, lengths of conveyors and Tank capacities. The Division <br />recommends reviewing the current Task 001 and looking at the inputs that are needed for the estimate. <br />The Division believes an appropriate place for this information would be as a new section of Exhibit 25 <br />or included in Table 56. Also a citation in the Mine Facilities portion of section 2.05 of the permit <br />indicating the location of this information needs to be added. <br />Response: Table 56, Map 25, and the "Mine Facilities" discussion in Section 2.05.3 of the PAP have been <br />reviewed, updated, and revised for consistency and to reflect the current disposition and status of all major <br />mine structures and facilities. Copies of these revised materials are included with these responses. It is MCM's <br />understanding that the Division will utilize this updated information to review and revise the reclamation cost <br />estimate, and will provide the revised estimate for MCM's review. Once the updated reclamation cost estimate <br />is finalized, a copy will be inserted in Exhibit 25. If the Division incorporates the relevant historical <br />information from the current cost estimate in this update, it will replace the current cost estimate in Exhibit 25, <br />otherwise, the current cost estimate will be retained as relevant historic background, and the updated cost <br />estimate will be added to Exhibit 25. <br />2) MCM Concern Task 018: Cover Mine No. 9 Portal Refuse and Facilities Area - +$104K (23 %) <br />a) This task was reviewed and the MT6 cost for this task was $444,656.73 and the RN6 cost was $551,287.20. <br />This is an increase of $106,630.47 (24 %). For this Task a D10 dozer was used to push the material. The <br />ownership cost per hour and the operating cost per hour increased from $80.89 to $110.68 and $147.96 to <br />$183.36 respectively. The operator cost per hour decreased slightly from $38.49 per hour to $37.41. Given <br />this, the total fleet cost per hour increased leading to a higher cost. Since the reclamation cost estimate was <br />conducted for RN6, the Division has updated our CIRCES cost estimating program with current costs. <br />Given this, the Division will re- evaluate and update the entire reclamation cost estimate. This cost may rise <br />or fall, it is unknown at this time. <br />3) MCM Concern Task 062 though 064: Revegetation Seeding - +102K (28 %) <br />a) The total reclamation cost estimated for these tasks for MT6 was $518,999.98 and for RN6 is $471,391.91. <br />Given this, the cost decreased $47,608.07 from the most recent cost estimate. As indicated above, the <br />Division will be updating the entire reclamation cost estimate and this cost may rise or fall. <br />4) MCM Concern: Significant increase in both the Job Superintendent hours and rate. <br />a) It appears the task hours associated with Task 001 was an error thus drastically increasing the Job <br />Superintendent indirect cost. This item will be addressed when the Division updates the reclamation cost <br />estimate. <br />5) MCM Concern: Increases in both the Engineering and M &A rates — 4.25 %to 5.23% and 3.25% to 4.00 %. <br />a) These percentages were changed approximately two years ago. These percentages used to be a straight <br />percentage of the estimate regardless of the amount of the direct costs. The engineering was 4.25% of the <br />direct costs and the M &A was 3.25% of the direct costs. By using a set percentage for these two indirect <br />