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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />September 29, 2006 <br />Angela Ballantoni <br />Environmental Alternatives, Inc. <br />402 Valley Road, Suite G <br />Canon City, CO 81212 <br />RE: Allen Drilling and Excavating Co., Inc. File No. M-2005-080 <br />Allen Pit 112(c) Surety Reduction Request (SR-01) <br />Deaz Ms. Ballantoni <br />RF~~~~ <br />~CT O F~ <br />°i~ison or 4?pub, <br />Mi~i~9 a aesa Patios <br />COLORADO <br />DIVISION OF <br />RECLAMATION <br />MINING <br />- &- <br />SAFETY <br />Bill Owens <br />Governor <br />Russell George <br />Executive Director <br />Ronald W. Cottony <br />Division Director <br />Natural Resource Trustee <br />The Division received a request for a surety reduction for the above permit, on September 19, 2006. The request <br />identified multiple items aimed at reducing the final bond amount for the site. The Operator should be aware that the <br />bond amount for the site is calculated to cover costs incurred by the state for reclamation of the site. Such reclamation <br />is typically performed by contractors hired by the state. Therefore the costs and considerations for the Division differ <br />than for those of the Operator who have resources available to him or her, for which the state will need to contract. <br />Listed below are referrals to the items in the request and the Division's response to these items: <br />1. Mobilize/Demobilize: The request letter indicates that the equipment needed for reclamation of the site can <br />be obtained in Fairplay -rather than Buena Vista - as was used as the nearest major city in the original bond <br />calculation. Although the operator has access to the necessary equipment for reclamation in Fairplay, the <br />Division is limited to equipment that is accessible to the state for use and to contractors available for <br />reclamation work to be performed for the state. Therefore the Division bases mobilization and <br />demobilization fees for acquisition of equipment on the neazest major cam. Fairplay is not considered a major <br />city in this sense. Therefore, the Division is required to utilize costs based on a larger radius than the distance <br />to Fairplay. The letter additionally inquires as to the need for a pickup truck - as was included in the original <br />bond. Reclamation performed for the state requires oversight by a supervisor or project manager. It is <br />common practice in bond calculation to supply this individual with transportation to, from, and around the <br />site. <br />2. Bulldozer Ripping Work: The request letter indicates that the area to be ripped for reclamation of the site <br />includes only the access road (approximately 0.5 acre) and the plant area (approximately 1.5 acres). The <br />original bond calculation included ripping of the pit floor, an additional 10 acres. The bond has been <br />recalculated for this portion of reclamation for the 2 acres requiring ripping. As a result, costs associated with <br />ripping work have been reduced from $3,017.00 to $508.00. <br />3. Grading: The request letter indicates that the reclamation plan submitted with the permit application <br />proposed to use a loader and dozer to grade the overburden and topsoil during reclamation, and the Division <br />estimate used only a dozer. The Operator proposes that use of a loader and dozer, rather than a dozer alone, <br />will reduce the costs and the time required for the grading work. The Division has recalculated this task <br />using a loader and recalculated the task using scrapers (see enclosures -Loader costs only -not including <br />mobilization and support dozer = $13,381; Scraper costs -not including mobilization = $17,118.00). Both <br />the use of a loader or scrapers exceeds the calculated costs for grading when using a dozer alone. Therefore, <br />it is more economical for the Division to use a dozer for reclamation, should it be necessary for the state to <br />perform the reclamation, and the Division would opt to use a dozer alone. Thus the bond amount should <br />reflect this anticipated cost, and the Division will continue to use the cost for grading with a dozer; alone, in <br />the calculated grading costs. <br />Office of Office of <br />Mined Land Reclamation Active and Inactive Mines <br />