2014-01-28_REVISION - C1981010 (2)

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Appendix A; Bond Estimate: The Division has reviewed the cost estimate submitted and it appears to account for the worst case disturbance for the next permit term. However, the estimate does not appear to take into account disturbance areas that have not been bond released. The Division cannot release liability associated with disturbed areas through the permit revision process. 25. The cost estimate provided by Trapper is broken up into reclamation tasks generally associated with a particular pit area (Ash Pit, D/E Pit, K/Gd Pit etc.). The Division could not locate a specific map which depicts the boundaries of these pit areas and their associated disturbance. Given this, it is difficult to verify disturbance acreages for a given pit. Since these pits designations are cited throughout the permit and used for cost estimate, please submit a map which depicts the disturbance area and the boundaries of each of designated pit areas. Trapper Response to Comment 25: A new map (map M4A) is enclosed which depicts the areas of disturbance and the boundaries for each of the pits. 26. In addition to item 20 above, it may also be helpful to include an additional table in the bonding section which lists each of the pit areas and their associated total disturbed acreages and the acreages that have been Phase I, II and III bond released. Trapper Response to Comment 26: As per the meeting on November 12, 2013 (and subsequent meetings & discussions) in which Trapper met with the Division to discuss the Phase Bond Release process as it pertains to the PR7 Worst Case Year Performance Bond, the additional table is no longer relevant and therefore has not been included with this response. 27. The cost estimate for regarding the Ash Pit does not include portions of Parcels A -B -10 and A -B -12 which have not received Phase I bond release. The Division cannot release liability associated with backfilling and grading through the permit revision. Given this, please revise the cost estimate associated with the Ash pit disturbance to account for the pit area that has not been granted Phase I bond release. Trapper Response to Comment 27: With the approval of SL -14 and SL -15 Phase I Bond Release areas, many of the issues addressed in this, and succeeding Adequacy Review # I items have been addressed. In addition, 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 also addressed. The PR7 bond estimate has been revised to reflect the addition of the Phase I and Phase Il Bond Release parcels s_parately from the perfonnance bond estimate for the worst case year of 2014. The Summary page (Table A -1 in Appendix A; Table 1.4 -1 in the permit text) of the PR7 Bond Estimate shows the costs associated with topsoil placement and revegetation for the Phase I and Phase II Bond Release areas preceding the areas of disturbance associated with the worst case bond year. 28. The current cost estimate includes a cost for re- grading the F -Pit. This cost appears to be based on volumes derived from cross sections submitted and associated with PR6 and the current Map M6. Portions of the F -Pit area associated with the current reclamation cost has not been Phase I bond released. The Division cannot release liability associated with backfilling and grading through the