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2.05.3 Operations Plan — Permit Area <br />DRMS Adequacy Review #4 issue: Based on Trapper's 2013 annual reclamation report, Trapper <br />identified a discrepancy in the accounting of cumulative disturbed acreage at the site. Based on <br />this the Division conducted a review of the permit to determine compliance with Rule <br />2.05.3(2)(a). Please address the following items: <br />I. Section 3.1.4.1 of the permit discusses the mining sequence. Map M4, M10A and M10B depict <br />the disturbance area boundaries for the next permit term. Rule 2.05.3(2)(a) requires the <br />maximum acreage proposed for each phase of the operations within the permit area be specified. <br />For each pit area that has been disturbed and is proposed to be disturbed, please indicate the total <br />area that has been disturbed and the maximum area to be disturbed during the 2013 -2017 permit <br />term. <br />II. Related to the item above, please specify the total disturbed acreage for the site in section 3.1.4.1 <br />of the permit. This acreage should be the total cumulative disturbed area acreage to date less the <br />area that has been Phase III bond release; plus the total proposed disturbance area for the 2013- <br />2017 permit term. This number will be the maximum about of disturbance approved for this <br />permit term. The purpose of this is to verify that Trapper has not disturbed acreage beyond what <br />they have been approved from year to year. The Division acknowledges that Trapper reports the <br />total acreage disturbed for each reporting year in the annual reclamation report. However, the <br />acreage reported in the annual reclamation report does not and should not include areas to be <br />disturbed in the future. The disturbed acreage reported in the ARR should always be less than or <br />equal to the total approved disturbed area acreage that the Division is requesting to be specified in <br />section 3.1.4.1 of the permit. <br />IIl. It appears based on Map M4, M10A and M10B, Trapper will be mining in the M Pit area. Please <br />add a discussion of mining in this area to section 3.1.4.1 of the permit and include the information <br />required in Rule 2.05.3(2). <br />a. Trapper's First Response: Enclosed Table 3.1 -3 has been revised and expanded in response to <br />Division comments I. and II. above. An M Pit mining area discussion was included in revised <br />permit page 3 -15a in our prior response to the Division to comment III. above. <br />b. DRMS Response: Revised Table 3.1 -3 does not completely address the items I. and II above. <br />Revised Table 3.1 -3 does not appear to account for E Pit, F Pit, Z Dip Pit, and AE Pit. For each <br />pit area please indicate the total area that has been disturbed to date that has not been Phase III <br />bond released. Also, please account for disturbed area that may not be associated with a pit such <br />as roads, ponds, diversions, etc. <br />Revised Table 3.1 -3 does not account for the total disturbed acreage at the site and this <br />information is not cited on revised page 3 -15a. This acreage should be the total cumulative <br />disturbed area acreage to date less the area that has been Phase III bond released plus the total <br />proposed disturbance area for the 2013 -2017 permit term. Based on the 2013 annual reclamation <br />report, at the end of 2013 there should have been a total of 3,326.4 acres of disturbance. The <br />Division is aware of an additional 2.3 acres of disturbance approved through MR220 affected at <br />Page 14 <br />