2014-01-28_REVISION - C1981010 (2)

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Trapper Response to Comment 31: As per the meeting on November 12, 2013, the issues regarding the release of liability associated with the Phase Bond Release process as it relates to the PR7 Permit Revision were addressed. See explanation for item # 27. With the PR7 Bond Estimate, the K, L, & M Pit's regraded surface (P.M.T.) incorporates a lower elevation drainage profile that facilitates a lower cost grading plan by reducing the overall volume required to bring the area to a post mining topography which provides positive drainage for the worst case bond year reclamation plan. This regrade design, combined with the dragline operation's placing the M and Q seam interburdens "in pit" (as opposed to hauling this material to the Horse Gulch Fill with the truck/loader operation) results in a lower volume of material required to backfill the worst case pit void. The truck/loader operation is utilized to move material that is too distant for the dozer grading operations to cost effectively push. This material is removed within the adjacent pit areas and does not take any material from the Horse Gulch Fill as was planned in the PR6 Worst Case Bond Estimate (see item #33 for truck/loader operations variance explanation). 32. The current cost estimate includes a cost for drilling and blasting the F Pit, Z -Pit, East A Pit and K- Pit. The proposed estimate only includes a cost to drill and blast the highwall associated with K/G Pit. Given that Phase I bond release has not occurred for the areas currently bonded for F Pit, Z Pit and East A Pit and that disturbance did occur in these areas, the proposed cost estimate needs to include a drilling and blasting the highwalls in F, Z and east A pit. Please revise the cost estimate to include this cost. Trapper Response to Comment 32: As per the meeting on November 12, 2013, the issues regarding the release of liability associated with the Phase Bond Release process as it relates to the PR7 permit revision were addressed (see item # 27 response). There is no highwall reduction drilling and blasting required for F or Z dip pits in that these pits have both been mined out, backfilled, and graded, and there is no final highwall to drill & blast. Therefore, no Drill & Blast costs are included in the bond estimate. With respect to F pit, there should never have been a highwall reduction drill & blast estimate submitted with PR6, in that F pit's final cut (which was in the worst case bond year of 2012) tied in to the spoils of the previously mined out Z strike pit on the east side of F pit. The last cut in F pit had spoil on both sides of the pit (i.e., no highwall). Z dip pit does not have a final highwall that requires drilling and blasting either. K strike pit intersects the final mined out cut (# 12) of Z dip pit from the southeast. K pit has advanced northward beyond the Z dip pit void which has been backfilled with the spoil generated from K pit mining operations. Thus, there is no highwall requiring drilling and blasting, and therefore, no costs for these activities were included in the PR7 bond estimate. AE pit drilling and blasting costs were inadvertently left out of the original PR7 Bond Estimate submittal. Approximately $75,000 has been included to cover the drilling & blasting costs for AE pit in the grading section of the bond estimate as requested by the Division (enclosed Table A -5.1). 33. The current cost estimate includes a cost to regrade the K -Pit using a truck/shovel team. Table 1.4- 2 in the current permit indicates the volume of material necessary to move for this task is 5,644,528 cubic yards. The proposed table A -4.4 indicates only 2,818,014 cubic yards of material is necessary to complete this task. This is a reduction of 2,826,514 yards. It does not appear that K -Pit parcels