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J. E. STOVER 8~ ASSOCIATES <br />2768 COMPASS DRIVE, SUITE 101 <br />GRAND JUNCTION, COLORADO 81506 <br />PHONE: (970) 245101, FAX 242-7908 <br />MINE ENGINEERING <br />MINE RECLAMATION <br />October 16, 2001 <br />sss <br />CIVIL ENGINEERING <br />CONST. MANAGEMENT <br />RECEIVED <br />OCT 12001 <br />Mr. Joseph Dudash <br />Division of Minerals and Geology <br />1313 Sherman Street, Room 215 <br />Denver. CO 80203 <br />Dear Mr. Dudash: <br />Division of Minerals 8 Geolony <br />Re: Bowie Resources Limited <br />Bowie No 2 Mine <br />PR-06 -Reclamation Estimate <br />Permit No. C-96-083 <br />On Behalf of Bowie Resources Limited, we aze submitting comments concerning [he <br />Division's estimate of reclamation costs as revised for PR-06. We have identified the following <br />items for evaluation: <br />Compaction (Task 1171 <br />The division offers a rationale that, because backfilling time exceeds compaction time, <br />$141,666 should be added to reclamation costs because of idle time associated with the <br />compaction machine. Bowie agrees that some additional expense is involved with this idle <br />compaction machine, but should not be charged for operational costs or operator costs <br />during this idle time. The division uses $119.69 x 1,183.61 hours = $141,666.28, Bowie <br />Suggests that the calculation should be $48.44 x 1,183.61 hours = $57,334.06, a difference <br />of $84,332.22. <br />2. Nuclear Densi Testing_of Backfill (Task 1161 <br />Bowie does not agree that "the technician is required to be on site for all of the <br />backfilling." Bowie azgues that it is not the backfilling that is tested, rather the <br />compaction of the backfill that is required. Furthermore, it is not the function of the <br />technician to ensure the compaction, but to provide evidence of the compaction of the <br />backfill material, and therefore the technician is not required to be present for all <br />compaction time. Bowie suggests that a more appropriate calculation for Nucleaz Density <br />Testing would be based on a percentage of compaction time (say 50%) times an hourly <br />rate (the Division's estimate of $69.30), rather than the total backfilling time x an hourly <br />rate. This method results in 441.45 hours x $69.30 = $30,592, a reduction of $112,617. <br />