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REV92465
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REV92465
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Entry Properties
Last modified
8/25/2016 3:13:53 AM
Creation date
11/21/2007 11:21:39 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981020
IBM Index Class Name
Revision
Doc Date
10/2/2001
Doc Name
LODESTAR 10/02/01 RESPONSES TO MUNGER TR-13 ADEQUACY LETTERS OF 7/31 AND 8/20/01
Type & Sequence
TR13
Media Type
D
Archive
No
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999 <br />Lodestar 10/2/01 responses to Munger TR-13 adequacy letters of 7/31, and 8/20/01. <br />1(a) and (b). amend text on page 2.1-1 and 2.2-14 to commit to completion of Loma Loadout final <br />reclamation and mine site interim reclamation by oo later than November 1, 2001... <br />ok. Amended pages 2.1-1 and 2.2-14 contain this commitment. <br />I(d). amend text in Section 3.9.3 to acknowledge placement ofcoaly material from McClane on <br />Munger bench, and specify placement against highwall in compacted lifts not to exceed 2 feet thick. <br />Also specify maximum volume of coal material. <br />The fact that some of the coaly material placed on the Munger bench came from the McClane yard area in <br />addition to the coal from Loma was not specifically addressed. But amended section 3.9.3 does specify <br />placement and compaction in compliance with appropriate requirements, and commits to inspection and <br />certification by P.E. as requested in letter of 8/20/01. A replacement page 2.2-12 was submitted, but it is <br />not clear why. The page was not requested and there are no apparent changes from the current permit page <br />2.2-12. Requested maximum volume of coal material to be placed against theMunger highwall was not <br />specified. <br />Lodestaz 10/03/01 response to our cost estimate and letter of August 11.2001. <br />Our cost estimate total was $175,596.00, which exceeded the current bond held by $2,673.00. In <br />Lodestar's response, they cite Task 10 (seal and plug portals) as having been completed, "which will <br />decrease the bond estimate by $3,807.00." They further cite Task 12 "conveyor gantry superstructure" of <br />405.25 which was not constructed, and "remove fan and portal arch" which "has been completed for an <br />additional $303.94.000. They conclude "These two items alone should save $4,516.19, which is more than <br />the $2,673.00 difference..." <br />1 don't think we can give "credit" for portal sealing andplugging or fan removal unless we do a phase I <br />bond release, since this would involve bond reduction based on satisfactory completion of reclamation. <br />Also, although 1 believe it is correct that the portals were sealed with foam seals some distance in from the <br />openings, 1 don't think the portals were permanently pluggedoutby the seals, but were rather temporarily <br />blocked with dirt pushed into the openings to block access into the portals during temporary cessation. <br />Permanent plugging would need to be confirmed before we could approve bond release. <br />The bond should be adjusted to reflect the conveyor structure that was never built ($405.25), but this <br />adjustment would still leave a deficit of over $2,000.00 <br />1 have a larger concem based on my review of our August 11, 2001 cost estimate and the previous midterm <br />estimate of August 1 I, 2000. The concem 1 have is that Reclamation Task IS (haul coal material from <br />loadout to mine), which was included in the prior cost estimate of January 8, 1997, does not appear to have <br />been included in the 2000 or 2001 estimates, although there is a Task 16, (Place material hauled fromLoma <br />Loadout at base of mine). Maybe this task I S was incorporated into one of the otherbackfilling and <br />grading tasks. 1'll check with Jim Stark to see if this was the case. Otherwise, it would appeaz that we will <br />need to amend our estimate to include the haulage, which will increase the apparent bond deficit by another <br />$5,476.00, at a minimum. (Although by now, the coal haulage may have been completed). 1 should have <br />caught this previously. In the 1997 estimate, there was a dvect cost of $ 11,500.00 for this task, which was <br />based on an estimated volume of 1,369 cubic yards ofcoaly material at the loadout. Our letter of February <br />3, 1997, contains the following explanation. <br />Based on measurements made by the Division at the Loma loadout, we estimate a total of /369 cubic yards <br />of cooly material, including 236 yards ojstockpiled coal, 314 cubic yards ofcoaly material on three ramps <br />in the loadout area, and 8/9 cubic yards ofcoaly material on the sarjace ojthe pad area. The estimate <br />
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