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<br /> <br />2,887,149 bank cubic yards of material which has not been appropriately accounted for. If all <br />maps that were provided to the Division reflect actual conditions, then this amount could <br />significantly alter the post mining topography. <br />Ultimately, this difference could affect the determination of the reclamation bond, so the operator <br />shoud carefully review the accuracy of the maps and make corrections where they deem <br />necessary. <br />4. Several issues arose regarding the reclamation cost estimate conducted for the permit term <br />1995-1999. It was determined from the operations plan map (Exhibit 12-f) that the highest <br />liability would occur in 1997. Specific comments regarding the cost estimate follow: <br />a. Seneca used equipment costs which date back to 1991 and ] 992. Please update the <br />estmimate with current equipment cost data. This update applies to all equipment used in <br />the estimate to reclaim the Yoast Mine. In the past, Seneca has used costs approved by <br />the Division. Attached are costs and production data worksheets, derived from the Cost <br />Reference Guide & Contractors Equipment Cost Guide, that Seneca Coal Company may <br />elect to use. <br />b. Seneca Coal Company estimated the cost to remove structures and facilities from the <br />Yoast Mine using the 1995 edition of Means. Please update the cost associated with this <br />task using the 1998 edition of Means. <br />c. The revegetation costs at the Yoast Mine also need updated. <br />d. Seneca Coal Company states that topsoil replacement volumes were based on the <br />volume of material in the stockpiles at the end of 1997. Seneca estimated the volume of <br />each stockpile based on a topsoil salvage depth over a particular azea. Please update the <br />reclamation cost estimate with the actual volume of topsoil in the stockpiles used in <br />reclamation of the worst case disturbance. Please update the topsoil tables and <br />reclamation cost estimate. <br />e. It does not appeaz that a cost for rip rap and underdrain material was included in the <br />original cost estimate for the permanent diversion (Attachment 20-1). Please update the <br />reclamation cost estimate to include rip rap and Mirafi 7700x armored erosion control, as <br />specified in the permit. We request that this diversion be named and shown on the <br />postmining map. <br />5. No regraded spoil sampling data has been submitted in ARR's to date, because no azeas <br />of final graded spoil were available as of the end of 1996. You should be awaze that <br />spoil sampling data will need to be reported in future ARR's. <br />The revegetation plan includes a commitment to include seed tags for all seedmixes used <br />in a given year, in the ARR. Although small areas of permanent seeding were completed <br />in 1995 and 1996, seed tags were not included in either of the annual reports. A seedmix <br />