2001-02-22_REVISION - M1977493 - Laserfiche WebLink

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Letter to Bryce Romig 4 February 22 2001 No. 7-Shaft Sealing DMG has included a cost for sealing 7-Shaft in the year 2001 re-estimate of reclamation costs. Once the documentation for the 7-Shaft seal that was discussed during the 9/26/00 inspection and described in the inspection report is submitted, the 7-Shaft sealing cost can be eliminated from the amount of required bond. 7. Buildings Demolition The DMG, through approval of Revision SR-03 releases CMC from reclamation liability for demolition and disposal of the Precon Building and No. 3-Thickner superstructures. The costs associated with these demolition tasks found on worksheet `c4b' in the Year 2001 reclamation cost re-estimate have been eliminated from the amount of required bond. Limitations to the release of reclamation responsibility for the demolition of these structures are as follows: • Fine grained, potentially acid generating residue (concentrates) at the No. 3-Thickner site may require relocation to the tailing ponds or other suitable disposal site. • The Precon Building and No. 3-Thickner foundations may require rubblization and backfilling or covering for final reclamation. • Revegetation responsibility release was not requested by CMC and is not included. Summary—Net Result of the Approval of Revision SR-03 on the Bond CMC's surety reduction request included with the SR-03 application totals $3,946,942.00. However, this amount was determined based in part on flawed accounting, and does not consider certain reclamation cost adjustments agreed to by DMG and CMC subsequent to the establishment of the current $52,434,637.00 bond. For the sake of efficiency, DMG requests that the bond amount be adjusted as appropriate one time rather than reducing the bond as a result of the SR-02 approval only to increase it again in another 60 days. The areas where the DMG has identified problems with the $3,946,942.00 reduction request are summarized here: • As discussed above, the assumption that Arkansas River cut material can be backfilled into the main body of the Storke Yard is no longer valid. Hence, the reduction in the backfilling and grading bond for Storke Yard based on a percentage of the total area completed is not appropriate and would compromise the amount of bond held by the Mined Land Reclamation Board. Re-estimation of the backfilling and grading costs based on current conditions has been completed by DMG and is incorporated into the year 2001 re-estimate. • Reduction of bond based on capping completed on Mayflower Pond in 1990 is inappropriate since a cost to cap areas outside the Mayflower water pool was not included in the bond submitted February 8, 1999. DMG's year 2001 re-estimate adjusts the geogrid cost for Mayflower based on CMC's current estimated acreage (218) requiring capping in Mayflower.