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COLOWYO COAL COMPANY L. P. <br />5731 State Highway 13 <br />Meeker, Colorado 81641 <br />(970) 824-1572 <br />(970)824-1598 FAX <br />~es A. Kilter <br />Senior Environmental Engineer <br />February 17, 1998 <br />``iii iiiiiiiiiiiiiiii <br />~= /~C//I/cti.vsa <br />/~ .Energy ~_, <br />Cc(oa-yo CoalCmapanyL,P. '~~;~~' <br />Mr. Byron Walker RECEIVED <br />Environmental Protection Specialist <br />Colorado Division of Minerals and Geology FEB 18 1998 <br />215 Centennial Building <br />1313 Sherman Street Division of Minerals & Geology <br />Denver, Colorado 80203 <br />RE: Colowyo Coal Company L.P. (C-81-019) <br />Technical Revision No. 43 <br />Response to Division Comments of January 7, 1998 <br />Dear Mr. Walker; <br />On January 7. 1998 Division provided correspondence to Colowyo addressing remaining technical <br />adequacy concerns regarding our TR-43 submittal. In particular, the Division was responding to <br />Colowyo's December 3, 1997 submittal. <br />Today, Colowyo is pleased to 1) address the Divisions concerns by offering the following comments for <br />• the Division's consideration and 2) submit the attached revised pages for inclusion into Exhibit 13. <br />Part C Exhibit 13 <br />11d. The current Colowyo estimate is based upon a 50 minute work hour (0.83 correction <br />factor) and utilizing 2 eight hour production shifts working five days per week. If the same correction <br />factors were used based upon the Division's example of 01/07/98 one would get the following <br />15 daylight hours x 0.83 = 12.45 <br />1 darkness hour x 0.75 = 0.75 <br />13.20 divided by 16 hours = 0.83 <br />The section of the Caterpillar Handbook {Edition 27, page 21-B) that talks about Job Efficiency also <br />talks about adjusting job efficiency based upon operator skill and other factors. The discussion ends <br />by saying that if no job data is available then utilize the .83 for daylight conditions and .75 for night <br />conditions. Colowyo's current estimate utilizes correction factors for operator skill levels and other job <br />correction factors, therefore the methodology of using 50 minute hours remains valid. <br />Colowyo recalls that the 1991 estimate was based upon an 83% job efficiency. A review of the <br />estimate details support this conclusion. The final 1991 estimate does, however vary by an agreed <br />upon amount for what is referred to as a CMLRD adjustment (page 21, for $62,073). While we were <br />never quite sure just what the Division factors were when we provided this contingency, it may have <br />• included an adjustment for this correction factor. <br />It is Colowyo's belief that the 0.83% Job Efficiency correction factor is a better estimate of the actual <br />job conditions for reclamation than the 48.6 minute, 0.81 % factor requested by the Division. <br />