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September 23, 2014 C- 1981 - 010 /Trapper Mine JLE <br />development drill holes will be managed and sealed in section 3.3.2 of the permit. Trapper has previously <br />provided abandonment reports for development drill holes to the Division. During the inspection, the <br />abandonment reports for holes drilled from 2010 to 2013 were reviewed. These drill holes were either <br />permanently sealed in accordance with Rule 4.07.3 of the permit or where mined through during the normal course <br />of mining. The holes that have been drilled in 2014 had not been sealed at the time of the inspection. According <br />to TMI, a data logger is used to evaluate each of the drill holes and when this is completed for the 2014 drill holes, <br />they will be sealed in accordance with the requirements of the permit. TMI indicated that this will be done in the <br />near future. Trapper is reminded that they must submit abandonment reports /proof of compliance for the 2014 <br />holes to be sealed within 60 days after abandoning the drill hole in accordance with Rule 4.07.3(3). <br />In regards to Rule 4.13, contemporaneous reclamation, according to section 3.3.2.1 of TMI's permit, for drill pads <br />where mining is imminent (will be mined within two years); reclamation will not be attempted since adequate time <br />for the site to revegetated properly would not have elapsed. During the inspection, the Division observed a <br />number of drill pads outside of the topsoil stripping limit of the mining operation that are older than two years <br />where reclamation has been completed. These drill sites include 2010 -AE3, 2010 -AE4, 2012 -AE4, 2012 -AE5. <br />Each of these pads has been reclaimed. TMI will need to evaluate which 2013 drill sites that will not be mined <br />through in the next year and will need to conduct reclamation of these drill sites in accordance with their approved <br />reclamation plan. Similarly, TMI should evaluate which of the 2014 drill sites will not be mined through within <br />the next two years and conduct reclamation on these sites. <br />Nineteen development drilling sites were observed during the inspection. A map depicting the location of each of <br />these drill sites is enclosed with this report. The Division collected a GPS point using a YUMA GPS unit at each <br />of the drill sites observed with the exception of sites 2010 -AEI and 2014 -M7. For the 2010 -AEI site, the GPS <br />unit indicated it had poor satellite geometry and a point could not be collected. The location of this site can be <br />found on the 2010 -2011 development drill hole abandonment reports. For the 2014 -M7 site, collection of the GPS <br />point did not occur, the location of this drill site can be observed on the map included with the Division's previous <br />inspection report for the inspection conducted on August 18 to August 20, 2014. The Division evaluated the <br />reclamation of sites that have been reclaimed, sediment control measures for each of the sites and general <br />compliance with the development drilling program approved in TMI's permit. In terms of sediment control <br />compliance with Rule 4.05.5, Trapper's sediment control measures for development drilling sites is discussed in <br />section 3.3.1 of their permit. <br />Overall, Trapper's drill sites that are located in areas outside of where topsoil has been stripped for the mining <br />operation are surrounded with dense vegetation and off pad sedimentation and erosion is extremely minimal. The <br />reclaimed drilling sites have dense vegetation established and rilling and gullying was not observed at these sites. <br />Trapper is required to construct a mud pit to contain water generated from the drilling operation. <br />A discussion of the observations at each drill site is below. <br />Site 2010 -AEI has been reclaimed and revegetated. Perennial grass has established on the site and the weeds on <br />site were minimal. <br />Number of Partial Inspection this Fiscal Year: 2 <br />Number of Complete Inspections this Fiscal Year: 1 <br />Page 4 of 13 <br />