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Bowie No. 2 Mine (C- 1996 -083) <br />MT- 4 <br />(3,068,041 CY, based on a conversion factor of roughly 1.3 CY of refuse per ton of <br />refuse) would be produced by the end of this permit term. <br />• The total design capacity of Gob Piles #2, #3, and #4 combined is 4,165,000 CY. Gob <br />Pile #4 has reached capacity. A generous estimate of the remaining capacity <br />(combined) in Gob Piles #2 and #3 would be approximately 1.5 million CY. <br />• Subtracting 1.5 million CY of remaining capacity in Gob Piles #2 and #3 from roughly <br />3 million CY of refuse expected to be produced between now and April 2017 <br />indicates that BRL needs to provide a plan for on -site disposal, off - site - disposal, or <br />both of approximately 1.5 million CY of refuse. <br />Please provide a plan, in accordance with Rule 2.05.3(8), for the disposal of all refuse <br />that will be generated through the current permit term. If our estimate of refuse <br />production and estimated remaining disposal area volume is in any way incorrect, <br />please let us know. <br />17. Please update pages 2.05 -44 through 2.05 -49 and /or Map 9 of the permit application <br />package to include a comprehensive listing of all underground openings (drill holes, <br />boreholes, exploration holes, and wells) including the diameter and depth of each hole, <br />the area of each pad, and the length and width of each associated road, in compliance <br />with Rules 2.05 and 4.07. <br />Section VII — Reclamation Liability and Performance Bonding <br />The Division estimates the current reclamation liability for mining operations to be <br />$12,446,699.61. The reclamation cost estimate summary is attached to this document. The <br />detailed reclamation cost estimate will be forwarded to BRL and is also available for review at <br />the Division office. <br />The reclamation cost estimate has increased due to the following: <br />• Equipment operating and labor costs have increased since the reclamation cost estimate <br />was calculated with the last permit renewal. <br />• The Division has included costs for rehandling of refuse in Gob Piles #2 and #3, <br />consistent with the current on- the - ground refuse handling operations. Since BRL has <br />permitted drying areas in both refuse areas, up to 425,000 CY of refuse may be loosely <br />stockpiled for drying at any given time. Currently, BRL excavates the material from the <br />drying area and trucks it across the refuse area for spreading and compaction. The <br />reclamation cost estimate now includes costs for this required rehandling. <br />• The Division included costs for nuclear density testing of drying area refuse as it is <br />graded and compacted. <br />After the Division reviews the information provided by BRL in response to Item 17, above, the <br />reclamation cost estimate may be further revised. <br />Page 15 of 22 <br />