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Trapper Mine; TR 115 <br />Page 2 <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 />as was planned nor will Trapper replace the amount of topsoil projected to be replaced in 2016 <br />for the KLM Pit area. Given this, Trapper will need to do the following: <br />The topsoil stripping and replacement plan shown on the TRI 15, M10B Sheet 3 <br />map does not appear to be consistent with the topsoil replacement that has <br />occurred for 2014 and 2015, nor what is projected to be replaced in 2016. Also <br />the 2015 Annual Reclamation Report Map depicts a proposed topsoil stripping <br />parcel for 2016 that is within portions of the 2016 parcel and portions of the <br />proposed 2017 topsoil stripping parcel depicted on Map MIOB. Please review the <br />topsoil stripping plan and replacement plan depicted on the proposed M10B map <br />and reconcile it with what has occurred to date and what Trapper plans in 2016 <br />and 2017. <br />Based on the item above, please review Table 3.1-3 on proposed revised page 3- <br />13 and make any necessary updates to the topsoil replacement balance for the <br />permit term. <br />Please evaluate the topsoil balance for the KLM pit and demonstrate in detail if <br />the cost estimate shown on Table A-10.6 is still adequate. Or, if necessary, please <br />update this table with a new cost associated with topsoil replacement of the KLM <br />pit. <br />It appears the KLM pit disturbed area is increasing in size as a result of TRI 15. <br />The reclamation cost estimate Table A-11.1 in Appendix A, shows a cost for <br />reclaiming 490.3 acres for the KLM pit. Please update this table to account for <br />the increase in acreage of the KLM pit. <br />