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.. _ • .} • <br />Mr. D. L. Damrau -2- February 25, 1983 <br />3. Concurrent Surface and Underground Mining and Variances <br />from Contemporaneous Reclamation: <br />In response to earlier adequacy comments from the <br />Division, the applicant has committed to the installation <br />of monuments and the performance of slope stability <br />monitoring within the vicinity of the proposed <br />underground portals. The applicant overlooked commitment <br />to submission of the monitoring results to the Division <br />for review. The applicant should amend the permit <br />application to include such a commitment. <br />Ponds, Impoundments and Diversions: <br />The applicant has decided to pursue a uniform sediment . <br />storage criteria as recommended in comment 7 of the <br />previous adequacy letter. The information is presented <br />in Exhibit 16a. The discussion states that the ponds <br />will be designed for the sediment yield from one 10-year, <br />29-hour storm event. Most ponds then provide additional <br />sediment storage with 60$ cleanout. CYCC appears to be <br />doing this, as shown in the Pond D calculations, but it <br />should be stated in Exhibit 16a for future pond designs. <br />In light of the fact that a revision will be submitted soon, <br />the reclamation plan and reclamation cost estimates will need <br />to be revised. As stated in the Technical Revision approval <br />dated February 14, 1983 regarding cost estimates, the <br />Division's equipment cost estimates were lower than CYCC's. <br />For 2 shifts per day, the base rate is multiplied by 1.5, and <br />for 3 shifts per day, the rate is 2 times the base rate. CYCC <br />is assuming 3 shifts per day in some cases and multiplying the <br />base rate by 3. The Division assumes 2 shifts per day, which <br />effectively cuts some of CYCC's equipment cost estimates in <br />half. All labor cost estimates by CYCC are $15.00/hr. The <br />Division bases labor costs on the base rates given in the 1983 <br />Means Cost Data Book. Therefore, the equipment cost estimates <br />and labor rates should be changed accordingly when the new <br />information is submitted. <br />