_ENFORCEMENT - C1981017 ‎(13)‎

• Permit No: C1981017
• IBM Index Class Name: Enforcement
• Doc Name: Bid Documents ‎(IMP)‎ Violation TDN 91-02-355-003
• Media Type: D
• Archive: No

Mr. Robert Hagen - 2 - October 28, 1991
The Division has historically estimated demolition and disposal costs based on
the Means unit costs , and, based on bond forfeiture projects we have
experience with, these unit costs are reasonable. Thus , the additional
handling and disposal costs are not appropriate.
The WSC estimate should be revised to reflect the 37 feet road width, and
exclude the $535,544.00 debris handling and disposal cost. Thus , the direct
cost for reclamation would total $2,423,308.00. This is less than the
Division' s original direct cost estimate of $2,431 ,530.00. Differences
between Division and WSC assessment of indirect costs would result in a grand
total of $3,036,405.00 compared to the MLRD estimate of $2,993,000.00,
resulting in a difference of less than 1 .5%. This difference is reconciled
given the nature of cost estimating procedures and associated assumptions .
Therefore, based on the site specific road width data, and a more practical
application of the Means demolition costs , we do not believe that a
significant bonding difference between our estimate and the WSC estimate
exists .
As always , we will continue to monitor the Coal Basin site. Should it become
apparent that re-evaluation of the bond is necessary, we will act quickly to
have the operator resubmit the appropriate bond. At this time, however, no
operator submittals are necessary nor is a Notice of Violation warranted.
I hope that this information is sufficient such that the AFO determines our
response to be appropriate. Please contact me or Dan Mathews if you have
questions or comments .
Sincerely,
Steven G. Renner
Coal Program Supervisor
SGR/scg
CC: Dave Bucknam
Dan Mathews
9029F