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1998-03-16_GENERAL DOCUMENTS - C1981017
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1998-03-16_GENERAL DOCUMENTS - C1981017
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Last modified
3/6/2021 10:57:17 AM
Creation date
5/2/2012 2:24:14 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981017
IBM Index Class Name
GENERAL DOCUMENTS
Doc Date
3/16/1998
Doc Name
Defendant's responses to DMG's initial discovery dated 02/02/1998
From
US District Court
To
Mid-Continent Resources Inc. & DMG
Permit Index Doc Type
General Correspondence
Media Type
D
Archive
No
Tags
DRMS Re-OCR
Description:
Signifies Re-OCR Process Performed
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17 Backfill Rock Tunnel to Prep <br /> Plant Area $41,632 <br /> 18 Rough Grade Entire Site $78,872 <br /> 19 Backfill Light Use Roads $4,498 <br /> Subtotal-Direct Costs $2,431,530 <br /> Contractor Overhead &Profit, <br /> DMG Project Administration <br /> Expenses S561,433 <br /> Total of All Costs $2,992,963 <br /> Because DMG's "projects" do not correspond with the reclamation categories <br /> contained in the permit reclamation bond and its 1991 mid-term review,it is impossible to <br /> state with accuracy whether "each of the reclamation projects" is required under MCR's <br /> permit. The best response MCR can provide is contained in the "Lezuicki Report", the <br /> Evaluation of Coal Basin Reclamation September, 1997 prepared by Gregory C. Lewricki, <br /> P.E.,Denver,Colorado,in six unnumbered letter-sized pages and eight unnumbered legal- <br /> sized pages, and provided to Third-Party Defendant December 9, 1997 pursuant to the <br /> Court's Case Management Order. <br /> Recognizing the inconsistency between DMG's permit bonding reclamation <br /> classifications, which classifications are stated above in this response and subsequently <br /> followed by DMG in the 1991 mid-term review of the permit bond,with the interrogatory <br /> "projects", MCR responds to the subparts of the interrogatory as follows: <br /> Part 1. Roads A,B,C,D, The road extending from the Coal Preparation Plant Site <br /> Huntsman (± 405 Ac.) westerly to and beyond the Rock Tunnels <br /> Lamphouse and to the saddle easterly of the Dutch <br /> Creek No. 1 and Dutch Creek No. 2 Mines portals <br /> should not be changed as it will be needed for post- <br /> mining uses. <br /> Part 2. Pond Removal The permit (Task #10) contains an item for sediment <br /> pond removal;however,it is our understanding that the <br /> Forest Service wants these ponds to remain as a <br /> sediment control measure and small areas of wetlands; <br /> for these reasons the sediment ponds should not be <br /> removed because of appropriate post-mining uses. <br /> MCR RESPONSES TO <br /> CML NO.97 cv 131-3 -5- DMG INITIAL DISCOVERY <br />
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