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COLORADO <br />Division of Recla:rnatio , <br />,. <br />Mining and safety <br />Department of Natural Resources <br />1313 Sherman S'tree't, Room 215 <br />Denver, CO 80203 <br />Memorandum <br />Date: March 28, 2016 <br />TO: Tabetha Lynch, DRMS <br />From: Jared Ebert, DRMS <br />RE: Trapper Mine; C-1981-010, Technical Revision 115 (TRI 15), Cost Estimate <br />I have conducted a review of the reclamation cost estimate regarding the proposed revision; <br />TRI 15. The proposed revision has several objectives, several of which may require an increase <br />in financial liability at the site. These are an increase in disturbed area by 49.7 acres for <br />additional topsoil stripping in the AE pit and KLM pit areas, the construction of a new building to <br />be used to store blasting vehicles and equipment, and the sealing of three monitoring wells. Each <br />of these items is discusses below and adequacy review issues are bulleted. <br />49.7 Acres of New Topsoil Stripping Area <br />TRI 15 proposes to add an additional 49.7 acres of topsoil stripping area for this permit term. <br />This area is depicted on proposed revised map M1OB, Sheet 3 as the 41.1 -acre 2017 topsoil <br />stripping parcel and an additional 8.6 -acre 2016 stripping parcel. Trapper Mine's liability is <br />based on an estimate to reclaim the site at the point of the worst-case disturbance during the <br />current permit term and liability associated with parcels that have been approved for either Phase <br />I and/or Phase II bond release. Trapper provided a new table to be included in Appendix A that <br />reflects what they believe the reclamation cost should be based on the activities proposed with <br />TRI 15. This table does not indicate a need to increase the liability to account for the additional <br />topsoil stripping at the site. The likely reason for this is due to some changes that occurred during <br />the review of Permit Revision No. 7 (PR -7). PR -7 originally included a 2017 topsoil stripping <br />parcel that was about 32 acres in size. When PR -7 was approved, the 2017 topsoil stripping <br />parcel was removed from approval, however the reclamation cost estimate was not changed to <br />reflect the removal of this parcel. <br />The proposed 49.7 -acre topsoil stripping area falls within the AE Pit area and the KLM Pit areas. <br />Upon review of Appendix A, Tables A-10.5 and A-10.6 which provides as cost estimate for <br />topsoiling the AE Pit and KLM pits respectively and the 2015 Annual Reclamation Report <br />submitted by Trapper Mine, the cost estimate to spread topsoil may no longer be adequate for <br />topsoiling the KLM Pit area. Based on Table A-10.6, the cost estimate includes a cost to apply <br />791,017 cubic yards of material to this pit area. Based on the topsoiling depth requirements, this <br />equates to enough topsoil for about 490 acres. After reviewing Sheet 3 of the 2015 Annual <br />Reclamation Report Map, it does not appear Trapper replaced as much topsoil in 2014 and 2015 <br />r`u <br />n 0 <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us " <br />John W. Hickenlooper, Governor I Mike King, Executive Director I Virginia Brannon, Director' ` ri <br />