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4. On Table 12-1 representing existing culverts, please explain the reason for the not applicable measurement of Diameter for culverts HG-9, HG-11, and HG-12. Map 12-2 show these culverts within the permit boundary as existing structures. Section 2.05.3(7)- Coal Handling structures Peabody is in compliance with rule 2.05.3(7) Section 2.05.4(2)(b)- Reclamation Cost Estimate The Division reviewed Peabody's cost estimate to reclaim the Hayden Gulch Loadout Facility. The Division has the following Concerns Backfilling and Rouah Grading 1. Peabody's performance bond estimate basis the operating cost for backfilling and rough grading using dozers on a double sktift. For a reclamation project the size of Hayden Gulch Terminal, the Division feels that a single shift is more appropriate. The Division has contacted several contractors regarding shift selection and has been verified that single shifts are the most ideal and realistic for this size project. Please change the equipment hourly cost to reflect single shifts rather than double shifts. The Division feels that an appropriate cost is $159.67/dozer. The Breakdown is as follows: Ownership cost/hr: $68.72 Operating & Overhaul/hr: $69.38 Operator cost/hr: $21.58 Please see the attached cost report and labor rates report for further clarification. 2. Using a single shift for backfilling and rough grading rather than a double shift, the correction factor for visibility can be change from a 0.90 to a 1.00. Please change this correction factor accordingly in the performance bond estimate. 3. Peabody estimated the volume of material to be backfilled using several cross sections of the HG Loadout Facility. Please submit a copy of the cross sections to allow the Division to verify the volume moved in the backfilling tasks. 4. Based on the Facility Map 12-1 submitted to the Division, there appears to be on average a 0~ grade. In Peabody's bond calculation a grade of -l0& was used to regrade all aspects of the mine. Please verify this grade with the Division. In submitting the cross sections as mentioned in item 2, the -10% grade may be more apparent. 5. Please indicate the average push distance to reclaim the Loop Track, the Spur Track, and the Facility Area. This push distance was not included in the performance bond estimate.