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J. J. Dudash - 2 - January 29, 2004 <br />Tasks 130 - 133 - Revegetation <br />BRL has concerns with the revegetation tasks, Nos. 130 - 133. The first is the cost of the <br />seed mix and mulching technique. BRL recently submitted an application for a minor <br />revision to adjust the seed mix and amend the mulching technique so a more realistic <br />revegetation estimate can be developed. <br />The second item of concern is the DMG's practice of increasing the seeding cost for <br />"estimatefailurerate". Rule 3.03.1(3)(a)statesthat"When determining the amount of bond <br />to be released, the Board or Division shall retain that amount of bond for the revegetated <br />area which would be sufficient for a third party to cover the cost of reestablishing <br />revegetation at any time during the period specified for permittee responsibility for <br />revegetation described in 3.02.3:' Thus, BRL believes that including an "estimate failure <br />rate" in the original bond and then holding back the cost of reestablish revegetaton amounts <br />to double bonding. <br />Task 158 -Yearly Site Maintenance and Pond Cleaning <br />No pond cleaning has been required at the Bowie No.1 Mine pond since the mine was idled <br />in 1997. The most difficult ponds to clean were Ponds 1 and 2. The sediment load in these <br />ponds was from wash down water from the crushing and screening building. Virtually no <br />sediment has built-up in Ponds 1 and 2 since the mine has been idle. This lack of sediment <br />buildup in sediment ponds at reclaimed or idle mines is supported by my experience at the <br />following reclaimed mines in the area, all of which have been idle for 10 years or more, <br />North Thompson Creek Mines, Blue Ribbon Mine, Red Canyon Mines, Coal Ridge No. 1 <br />Mine and the Hamilton Mine. None of the sediment ponds have required cleaning at any <br />of the mines listed above. I believe the DMG could reduce the pond cleaning cost estimate <br />to a total of five cleanings for the liability period. <br />Task 210 -Reseed Unit Train Loadout and Coal Stockpile Area <br />The seed mix used is not correct. Please refer to Volume 7, page 2.05-25. The approved <br />seed mix is; 30% Regar Meadow Brome, 25% Potomac Orchardgrass, 25% Brome Grass, <br />20% Tetraplloid Perennial Rygrass with a seeding rate of 30 to 35 pounds per acre. <br />Task 203 Demolish and Remove Structures at Train Loadout <br />The last item in the table is for concrete disposal charges. The estimate allows for <br />disposing of concrete off site. BRL intends to bury the concrete on-site so this item could <br />be removed from the reclamation estimate. <br />Please call if you have any questions. <br />Sincerely, <br />~~~ <br />J. E. Stover, P. E. <br />Consulting Engineer <br />