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H. GVC has not used a Motor Grader to final Grade those slopes over <br />lOX because, early in the life of the permit, the division <br />required GVC revise the original reclamation plan to enhance <br />moisture retention in the mine area. Included within this plan <br />is a provision to leave the surface somewhat rough, see Page <br />3-12, also see Section 3.3.1. Additionally, slopes greeter than <br />lOX would present a tipping ha2erd when final grading with a <br />motor grader. The areas that are not final graded with a motor <br />grader will be left somewhat rough after recontouring with the <br />dozer. <br />I. Task 13, Regrade Diversion Ditches, has been added to the <br />calculations. <br />J. GVC has adopted the Division's factors. <br />K. N0. The Divisions estimate is wrong for many reasons. The <br />sealing plan used by the division is extremely over designed. <br />As noted on GVC's calculation sheet for Task 18A the design of <br />the seals for McClave Canyon Mine was approved by MSHA in <br />accordance with the regulations in 30 CFR 75.1711-2. The <br />regulations do not even require the use of seals. GVC has <br />decided to use seals as an additional measure. The portion of <br />the approved ventilation plan regarding final seals has been <br />added to Appendix B. The approved plan differs significantly <br />from the design that the Division adopted. Significant among <br />these differences are the amount of hitching into the rib, the <br />use of cinder block rather than solid concrete block end the <br />lack of pilaster. <br />Utilizing GVC's approved plan results in significant material <br />end labor savings over the design that the Division uses. <br />The division also uses the highest bid for this type of work to <br />calculate this cost. See Paragraph 2 of Mr. Sorenson's memo <br />dated February 10, 1993. <br />L. GVC cannot agree with some of the factors that the Division used <br />to Berate the productivity of the D-4 dozer. First, the <br />material used to backfill the portals will be excavated during <br />normal regrading activities at the mine site. The swell factor <br />for this materiel has been accounted for in that excavation. <br />Swell will then be 1.00. The distance that the material will be <br />pushed will be a maximum of 50 feet not the 100 feet that the <br />Division uses. Since the materiel will be stockpiled et the <br />portal, the materiel consistency should be adjusted from 1.0 to <br />1.20. There is no justification for using a below average <br />operator oa the machine. The backfill operation is not taking <br />place in the deep dark reaches of a mine but at the portal. The <br />average distance that the material will be pushed into the mine <br />is 12.5 feet; about the length of the machine. This will not <br />present a visibility problem for the operator; visibility should <br />not be Berated. <br />Mc Page - 4 7/12/94 <br />