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~, <br /> <br />page 2.05-57, that explains the sealing method for the gob de-gas boreholes. <br />Please provide revised text that explains BRL's plan for disposal of drilling mud. If the <br />drilling mud is to remain onsite, please provide a discussion, which includes a chemical <br />analysis of the drilling mud, that explains why the drilling mud would not harm the <br />environment. Also, please explain whether or not the mud pits will be lined. <br />6. Please note that the approved plan for construction of the mud pits calls for excavation <br />into the drill site bench. No embankments should be used to impound the drilling mud. <br />Attached is the Division's reclamation cost estimate for TR-20. The total liability <br />estimate is $194,638.00, which is $58,176.00 higher than BRL's estimate of $136,462.00. <br />One of the reasons for the difference is increased costs. The estimate submitted by BRL <br />used costs from Permit Revision No. 3 (PR-3), which was completed in September 1999. <br />Costs for equipment and seeds have increased since that estimate was prepared. For <br />example, in the PR-3 estimate, a CAT D8R Dozer had an hourly cost of $122.02. The <br />new hourly cost for the same dozer is $143.48. There is a similar increase in seeding <br />costs. In the PR-3 estimate, the cost per acre to reseed was around $1,567.00. This cost <br />has increased to $1,983 per acre. <br />It also appears that BRL did not include costs such as liability insurance, contractor profit, <br />administrative fees etc. These costs, based on the Division's estimate, accounted for an <br />additional $40,515.00 (or 25% of the direct costs). <br />Please review the Division's reclamation cost estimate and comment on whether it is <br />acceptable to BRL or not. <br />If you have any questions, please call me. <br />Sincerely, <br />CI D,.~ <br />seph J. Dudash <br />Environmental Protection Specialist <br />Attachments <br />cc: Jim Stover P.E. (J.E. Stover & Associates) with attachments <br />c:\ms97\bowie2\tr20adeq 1 <br />