2014-02-27_REVISION - C1981010 - Laserfiche WebLink

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Trapper Mining, Inc. C- 1981 -010; PR7 Adequacy Review No. 2 Page 11 of 15 The PR7 bond estimate lias bee�i revised to reflect the additio�i of the Phase I and Please 11 Bond Release parcels se ¶aaaratellv from the perfonna�ice bond estimate for the worst case, ear of 2014. The Summary page (Table A -1 in AppeMri A; Table l.4 -1 iu the pennit text) of the PR7 bond Estimate shows the costs associated with topsoil placement and revegetatioee for the Phase I and Phase 1[1[ bond Release areas preceding the areas of disturbaeece associated with the worst case bond year. b. Division's Response: The Division is conducting a cost estimate based on our November 12, 2013 meeting and the subsequent approvals of the SL 14 and SL 15 bond release applications as well as the revised information submitted. 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 PRO 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 permit revision. Given this, please revise the cost estimate associated with F Pit to account for the pit area that has not been granted Phase I bond release. a. Trapper's Response: See etplaeeatioui one item ff27. b. Division's Response: The Division is conducting a cost estimate based on our November 12, 2013 meeting and the subsequent approvals of the SL 14 and SL 15 bond release applications as well as the revised information submitted. 29. The current cost estimate includes a cost for re- grading the Z dip -Pit. This cost appears to be based on volumes derived from cross sections submitted and associated with PRO and the current Map M6. The Z dip -Pit area associated with the current reclamation cost has not been Phase I bond released. The Division cannot release liabilitv associated with backfilling and grading through the permit revision. Given this, please revise the cost estimate associated with Z -dip Pit to account for the pit area that has not been granted Phase I bond release. a. Trapper's Response: See etplaeeatioee one item ff27. b. Division's Response: The Division is conducting a cost estimate based on our November 12, 2013 meeting and the subsequent approvals of the SL 14 and SL 15 bond release applications as well as the revised information submitted. 30. The current cost estimate for the AE Pit is based on backfilling 879,238 cubic yards of material. The new estimate is based on a cost for backfilling 471,746 cubic yards of material. This is 407,492 cubic yards less than the current estimate. It does not appear area within AE Pit has been granted Phase I bond release. Please explain this large decrease in volume needed to backfill this pit. a. Trapper's Response: ]fie PR6, the bond Estimate for Last Aslnnore pit (AE pit) involved the grading of the proposed cut # 49, ee leicle is approtimatele 550 fi, east of the cut (# 45) that presentl exists in AE pit. At the time that PR6 was submitted, Trapper had more aggressive plans for the development of AE pit and therefore the worst case sceeea rio for this pit was several cuts farther to the east tleaee where it has beeue developed to date. At this time, there are eeo plans to ade aeece AE pit be�-oM the existing cut (# 45) in the current 5 Year permit term. Therefore, final grading for the existing cut was estHnated and reported in the PR7 bond Estimate. The cut that is addressed in PRO, requires a greater volume of backfill due to being located farther eastevard (than the existing cut urefereeeced in PR7). The greater overbu rde�e depths (i.e, higher sturip ratio) associated evith higher elevatioue terrain to the east, results iu the higher grading volume. Eveee