1999-04-25_GENERAL DOCUMENTS - C1981017

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4. During the entire 1993 season, I spent considerable time in negotiating with the DMG officials, who, under much pressure from the United States Office for Surface Mining ("OSM"), were issuing violations at a considerable pace throughout the mine area. Many of these violations were questionable and were later revoked by arbitrators within the Division, however, at the time that they were issued, they demanded immediate abatement action on the part of Mid-Continent. If immediate action was not taken, cessation orders could have been issued, which carry fines of up to thousands of dollars per day. I was involved with the abatement of many of the violations. 5. In the winter of 1993, I planned the reclamation of the other portal areas, the Sutey Pile and the road system on the site. In the early summer of 1994, I received bids from various contractors to begin the reclamation. Our selected bidders were required to submit company information to the DMG, all of which was later approved by DMG official, Steve Renner. I also was involved in the continuing of active reclamation work until work was stopped by the DMG, who took control of the site at the end of July 1994. 6. Based on my qualifications and experience on the site during the time of the Pitkin Iron work, I feel that I can make an accurate estimate of the validity and costs associated with this work. II. Estimation of Costs,for Pitkin Iron Task Work Completed A) Explanation of 12 Work Tasks 7. The spreadsheet included in Appendix A divides the work accomplished by Pitkin Iron personnel and equipment into 12 tasks, all of which were a direct benefit to the MCR estate. Only that work from the September 1, 1993 to June 30, 1994 was considered. 8. Each of the tasks are listed below: a. Task 1 - Abatement of NOV C-93-086 which involved repair of the Dutch Creek Flume. Haul steel 8' diameter tubes from upper portals, install in flume on a new reinforced concrete base. Weld tubes and install rounded transition entrance of reinforced concrete. Considerable labor was involved in this work, especially due to cold conditions which slowed concrete work. All work was approved by the DMG. b. Task 2 - Work on regrading areas of the Rock Tunnel Pile, Old Refuse Pile, and Raw Coal Pile area for final reclamation. Work also included re-channeling ditches and water discharges from the Rock Tunnel and the ponds around the Rock Tunnel Pile. C. Task 3 - Abate violations to reclaim terraces on the Sutey Pile and mark the perimeter boundary of the mine. 2