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2016-10-27_REVISION - C1981041 (3)
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2016-10-27_REVISION - C1981041 (3)
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Last modified
10/28/2016 6:54:31 AM
Creation date
10/28/2016 6:30:02 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Revision
Doc Date
10/27/2016
Doc Name
Review of Liability Reduction Calculation
From
DRMS
To
Snowcap Coal Company
Type & Sequence
SL9
Email Name
JLE
DIH
Media Type
D
Archive
No
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* 1— Task 131, SCC requested $17,301.24 and 18.2 hours to be released for this task. However, Pond 11 was withheld from Phase III bond release <br />and this the liability associated with revegetation of this pond was not removed from this task. <br />*2 — Task 204, SCC requested a reduction of $5,930.78 and 72.3 hours for this task. The requested amount includes dollars and hours for <br />maintenance to be conducted on the CRDA 1 Access Road (1.2 acres) and all of the ponds/sediment control features. However, the CRDA 1 <br />Access Road and Pond 11 will not be Phase III bond release with the approval of SL9 and the liability for maintenance of these features must be <br />retained. <br />*3 —Task 205, SCC requested a reduction in the mobilization cost for this task based on the number of acres being requested for Phase III bond <br />release with SL9. SCC indicates that 44.6% of the remaining affected acres at the site will be Phase III bond released with SL9, thus this task <br />should be reduced by 44.6%. However, the Division must hold enough money to mobilize the equipment to the site to complete reclamation on <br />area not released from bond. Based on the tasks remaining in the cost estimate that have not been bond released, the Division would need to <br />mobilize the equipment listed in Task 205. Given this, no money or hours will be release with this task for SL9. <br />*4 — Task 206, similar to item *3 above, SCC requested this task be reduced by 44.6%. However, this task is based on the number of times the <br />Division would have to mobilize equipment to the site (1 time/year) during the remaining liability period for the reclaimed parcels. At this time <br />about four years remain in the liability period for the CRDA No. 1 Road and the CRDA No. 1 re -disturbance area. Given this, at a minimum this <br />equipment would be mobilized four times to conduct maintenance. Prior to the approval of SL9, the cost estimate included a c ost for mobilizing <br />equipment to the site seven times, with the approval of SL9 this task can be reduced by the cost to mobilize equipment three times. <br />*5 — Task 107, $331.70 is retained for this task. SCC requested Phase II bond release on 2.8 acres of land. In accordance with Rule 3.03.1(2)(b), <br />up to 85% of the applicable bond shall be released upon establishment of vegetation which supports the approved postmining land use. Given this <br />requirement for Phase II liability, the Division can only release 85% of the applicable bond for this parcel. The areas requested for Phase II bond <br />release were released from Phase I (60%) liability with SL8. The applicable bond for this parcel is based on the total liability estimated for the site <br />prior to bond release. In the case for this parcel, the PR5 cost estimate set the liability for the site prior to SL8. The table below depicts how the <br />85% applicable bond was calculated for the 2.8 acre Phase II bond release parcel for SL9. The remaining 25% (85%-60%) of the applicable bond <br />available for Phase Il bond release is $3,706.75. Using the Division's December 3, 2015 cost estimate, the total Phase II liability (topsoiling cost) <br />for the 2.8 acres parcel was estimated to be $4,038.44 including both direct and indirect cost. This amount is $331.70 more than the Division can <br />release per Rule 3.03.1(2)(b), thus this dollar amount was retained. <br />
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