REV17192 - Laserfiche WebLink

Home Browse Search

September 1, 2004 The task that required the Table on page A-4 is no longer necessary, hence the zero values in the revised table. No further response is necessary from the operator. 4. Appendix 13, revised table A-6 shows that no new topsoil stockpiles have been created or utilized since 1997. Since mining has progressed over the past 6 'h yeazs, the Division questions if the topsoil stockpile values aze currently correct for 2004? Colowyo responded that topsoil volumes have not been updated to reflect 2004 worst-case. The worst- case disturbance scenazio is still based on 1997 worst-case disturbance. The Division acknowledges that the 1997 worst-case" disturbance scenario was likely a larger amount of unreclaimed disturbance than the unreclaimed disturbance existing on the mine site in 2004. Colowyo has declined to update Table A-6. The Division can accept the 1997 values. 5. Colowyo submitted revised Appendix 13, C-1, C-la, and C-lb. These hourly equipment rates vary significantly from the Division's CIRCES hourly equipment rates. DMG last updated the CIRCES program rates in 2003. These values are obtained from second and third quarter 2003 values provided by Colorado Department of Transportation, Cost Reference Guide (CRG), and the Contractors Equipment Cost Guide (CECG). DMG's comments dated 8/8/2003 to Colowyo: 1) Exhibit 13, page iii of TR-56 provided references of resources used by Colowyo to develop the reclamation cost estimate. The most recent data used by Colowyo is six years old or older. Equipment and labor costs change significantly form yeaz to yeaz. Please have the operator revise Colowyo's reclamation cost estimate using current equipment and labor costs. 2002 data is available and would be found acceptable to the Division. Colowyo's submittal, dated October 23, 2003, provided equipment unit costs updated using 2002 resources, 2002 Cost Reference Guide for Construction Equipment, U.S. Department of Labor, and Davis Bacon wage rates for Western Colorado. These values will be acceptable to the Division for TR- 56. These rates will need to be updated the next time the reclamation cost estimate is revised. Colowyo's May 3, 2004 reclamation liability estimate totaled $19,171,621.00. This value is $2,857,276.00 higher than that previously submitted by the operator in September 2003. Based upon the Division's review and cost estimate of compazed reclamation tasks, the Division accepts Colowyo's reclamation cost estimate value. The Division currently holds bonds totaling $16,000,000 (016-029-909 and 016-029-910 drawn on Liberty Mutual Insurance Company). Colowyo will need to submit additional bond in the amount of $3,171,621 to bring the bond held by the Division into agreement with the projected reclamation costs associated with approval of TR-56.