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New Elk Mine C1981012 MT6 updates 7 January 18, 2013 <br />#37: Please see the Division's response to #19. The Division has adjusted failure rates for seeding tasks to <br />33 %. The Division acknowledges that NECC has had commendable revegetation success in the past, and <br />reminds NECC that application for Phased bond releases for successful reclamation is encouraged in order <br />to reduce the permittee's reclamation liability. <br />Topsoil Balance: The Division requested NECC provide a topsoil balance for actual topsoil available on -site <br />in relation to topsoil required to complete the approved reclamation requirement. NECC has not yet <br />provided the Topsoil Balance verified volume. Based upon the calculated topsoil replacement <br />requirements; 9 inches on DWDA #2 and RDA, average 5 inches on facilities areas identified as "DR" <br />(disturbed refuse), and zero topsoil replacement on facilities area identified as "DNR" (disturbed no refuse), <br />the required replacement topsoil volume equals 58,819 LCY (Calculated from volumes used in RCE update). <br />The Division requires verification of the actual topsoil volumes available as shown in Table 24, and where <br />this topsoil is currently located. <br />The Division estimated total topsoil volume available based upon the existing topsoil stockpiles currently <br />(January 2013) existing on the mine site equals 26,135 LCY. This would result in a deficit of 32,684 LCY <br />topsoil to complete the required topsoil tasks. Based upon Division experience in the Las Animas County <br />area, the cast to procure and import topsoil runs approximately $10 /cubic yard. Adding cost for <br />importation of topsoil based on a projected deficit of 32,682 loose cubic yards will add $326,820.00 to the <br />reclamation Cost Estimate. <br />The following tasks were updated or revised based on further review by the Division and may not have <br />been specifically questioned by GEC. <br />Task 170 and Task 171 are duplicates of Task 162 and Task 165. Task 170 and Task 171 have been <br />eliminated. Task 163 is already covered in Task 027. Task 163 has been eliminated. <br />Combine several small grading tasks together: Task 133 involves grading 3 development drill pads <br />approved with MR107. (370 LCY, 1 D7R DS dozer, 50 ft. push Earth dry packed - $141.62) Task 135 Backfill <br />and regrade test pits and access roads associated with MR99 (800 Icy, 1 D6T LGP, 50 ft. push 25% rock 75% <br />earth - $723.07), Task 137 Backfill and regrade Ditch D26 extension approved with MR111 (463 Icy D3K LGP - <br />3P, 50 ft. push, 25% rock 75% earth- $616.54), Task 146 regrade 6 drill pads and mud pits approved during <br />MR114 (3,903 Icy, D7R DS II LGP, 50% rock 50% earth, 125 ft. push - $4,683.08) Combine all these tasks into <br />Task 133. Task 135, task 137, and task 146 have been eliminated. Task 002 was a duplicate of Task 137. <br />Task 002 has been eliminated. <br />Task 157: Culverts and powerline additions approved with TR62. This task has been included as line items <br />in Task 095, and powerline length is included with the total length of powerline removal. Task 157 has <br />been eliminated. <br />Task 156: Incorporate removal of culverts found in task 156, approved with TR60, into Task 095. Task 156 <br />has been eliminated. <br />