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MR -221, Approved 12/12/2014. Blasting record summary from and air blast monitor location <br />revision. <br />Violations <br />A Notice of Violation was issued on 8/26/2014 resulting from an inspection on 8/18/2014. The <br />primary topic was topsoil. The secondary topic was sediment control. The NOV was abated <br />9/25/2014. <br />Permit Stipulations <br />Permit renewal RN -06 was approved on 8/28/13 with the following stipulation. <br />Stipulation No. 21: THE OPERATOR MUST SUBMIT AND RECEIVE APPROVAL FOR A <br />PERMIT OR TECHNICAL REVISION TO UPDATE THE DRAINAGE AND SEDIMENT <br />CONTROL PLAN PRIOR TO ANY DISTURBANCE OUTSIDE OF THE CURRENTLY <br />APPROVED DRAINAGE AND SEDIMENT CONTROL PLAN BOUNDARY. <br />All previous stipulations have been complied with or incorporated into the Permit Application <br />Package as permit commitments during previous Midterm or Renewal actions. <br />Additional Midterm Review Items <br />The Division reviewed another item that has no specific requirement in the Regulations <br />requiring their review. Regarding the timing of backfilling and grading (Rule 4.14.1), TMI has <br />been granted a variance from the requirement that this operation be performed within 180 days <br />after coal removal. This variance was granted in the approval of a permit revision in 1988 <br />(PR -02). <br />Regarding the D/E Pit, which has been temporarily abandoned and left open for an extended <br />period of time, a plan to use this pit for utility waste disposal (ash from the Craig Power Plant) <br />has been approved (as discussed in PR -02). <br />Bond <br />The Division has reviewed the reclamation cost liability for the Trapper Mine permit. The cost <br />estimate enclosed is based on the tasks from the RN6 estimate and has been updated based on <br />present day costs as well as taking into account the approval of SL14, 15 and 16 and MR220. <br />For MT7, the liability estimated for the Trapper Mine is $24,738,005.49. The current liability <br />is set at $27,030,843.72 and TMI currently has a corporate surety in place in the amount of <br />$30,173,724.00. The liability estimated for MT7 is less than the liability currently in place for <br />the Trapper Mine; thus TMI does not need to increase their bond. The primary reason why the <br />liability estimated for MT7 is less than the currently set liability amount is in regards to Task <br />No. 025. Utilizing more efficient and less costly equipment, the liability estimated for this task <br />was reduced. Other unit costs increased or decreased depending on the task but the overall <br />Trapper Midterm 2015 Findings TNL_2.docx Page 5 <br />