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k. Task 11 - Removal of transformers at all mine areas and properties in <br /> Carbondale. Work involved preparing, gathering, loading and hauling all electrical transformers <br /> and associated equipment off the site for final reclamation. Considerable work was involved in <br /> preparation and handling of the PCB oil transformers on the site. No costs for actual disposal <br /> of the transformers was charged by Pitkin Iron. MCR paid this very expensive cost. <br /> 1. Task 12 - Sale preparation of all offsite properties including Fabrication <br /> Shop (A& C Shop) and the Industrial Park in Carbondale. Work involved removal of all debris, <br /> waste oils, general cleanup and assistance in the environmental audits including soil testing, <br /> borings, etc. This work was valuable to the estate since it allowed the properties to be sold at <br /> an earlier date. <br /> 9. All of the above tasks involved legitimate work which was absolutely necessary <br /> and accomplished in the most efficient manner possible. <br /> B) Explanation of General Spreadsheet Input Parameters <br /> 10. The spreadsheet of costs (Appendix A, attached) is an attempt to quantify the <br /> legitimate work accomplished by Pitkin Iron personnel and equipment during the disputed time <br /> frame. The spreadsheets have been formulated under the following assumptions: <br /> a. Assume that the work was not done by Pitkin Iron but was done by another <br /> contractor. Although most contractors refuse to run equipment owned by another party, <br /> Case 1 conservatively assumed that all MCR retained equipment would be used by the <br /> contractor. This is important since all owning costs for this equipment are not charged <br /> to the task costs, although they are shown for reference in the spreadsheet. Case 2 <br /> assumes that a contractor would not use the MCR equipment but would bring in extra <br /> machines to replace the MCR equipment. On these machines, owning costs per hour are <br /> included in the totals. <br /> b. Almost all owning, operating and labor costs have been extracted from the <br /> DMG's own bond estimating procedures. A few costs such as those for the John Deere <br /> backhoe and the Cat 16G motor grader were made from Caterpillar handbook estimates <br /> and past experience with contractors. <br /> c. Revegetation costs were also taken from DMG bond calculations and past <br /> experience. <br /> d. The hours for each item were taken directly from the Pitkin Iron timesheets <br /> for each employee on an hourly basis. It is assumed that the hours charged for each task <br /> involved legitimate work. From my involvement with the actual work at that time, and <br /> from past experience on other sites, I believe that the hours charged were legitimate. <br /> 4 <br />