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ENFORCE25961
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ENFORCE25961
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Last modified
8/24/2016 7:34:06 PM
Creation date
11/21/2007 11:10:42 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980006
IBM Index Class Name
Enforcement
Doc Date
9/9/1994
Doc Name
MEMO COMMENTS ON OSMRES LETTER FROM ROBERT URAM TO ROY ROMER
From
DMG
To
KERR COAL CO FILE C-80-006
Violation No.
TD1994020352002TV1
Media Type
D
Archive
No
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<br />OSM/Western Services Center (WSC) also conduct an independent analysis of current reclamation <br />liability relative to the most recent aerial photography volumetrics data and the approved backfiling <br />and grading plan". <br />The W SC did conduct an analysis of the backfilling and grading plan. A portion of the results of the <br />analysis were relayed to the Division by a telephone conversation between Mr. Austin and Mr. Price. <br />However, Mr. Austin would not release a copy of the study because as he claimed it was an internal <br />memo and that he would have to check with his supervisor. The Division did not receive a copy of <br />study until March 3, 1994. <br />The Uram letter states that the WSC study "concluded that there could be a substantial shortfall" of <br />backfill. Contrarily, the WSC study found that the opposite was true. The study stated that of the <br />15,384,000 yds2 of material removed from both pits there would be a shortfal1399,840 yds. This is <br />hardly a substantial shortfall; this is only a shortfall of 2.8%. Mr. Inman also qualifies his calculations <br />by stating that comparing the deficiency to the Kerr Coal Company's calculations "can be caused by <br />an inaccurate swell (24%) factor or an incorrect pit void volume for Pit 720." The report does state <br />on the third page that "Using the available information it appears that the stockpile does not contain <br />sufficient yardage to backfill both pits (720 & 1) by approximately 400,000 CLCY." However, the <br />report does not even consider the difference an important enough factor to mention any problem with <br />attainment of AOC in the Summary of Findings and Conclusions on the cover page of this document. <br />
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