Laserfiche WebLink
TR -115 Response Cont. <br />Page 2 of 8 <br />on the maps themselves. Ultimately any area within the proposed stripping boundary could be <br />stripped within the permit term. To remain consistent with long-term protocol, along with <br />providing a demonstration of the worst case bond scenario, the MIO maps should not be modified <br />as requested. The ARR maps propose year to year fluctuations in operations. <br />The projections of stripping and reclamation were established based on a worst case scenario in <br />2014 and annual mine production of 2.6 mty. This has not been the reality . for Trapper, and <br />mining advancement has proceeded at a slower rate than this. Limitations due to legal action <br />taken by Wild Earth Guardians against the Of of Surface Mining also limited our stripping <br />area over the past year. Due to this variability, stripping and proposed reclamation have been <br />offset due to fewer yards being transferred via the truck and loader fleet to the K -Strike area as <br />backfill. These_factors have not allowed Trapper the ability to re-establish the necessary PMT in <br />that pit area in order to perform the projected reclamation. <br />The topsoil stripping and replacement plan shown on the TRI 15, M1OB Sheet 3 map does not <br />appear to be consistent with the topsoil replacement that has occurred for 2014 and 2015, nor <br />what is projected to be replaced in 2016. Also the 2015 Annual Reclamation Report Map depicts <br />a proposed topsoil stripping parcel for 2016 that is within portions of the 2016 parcel and portions <br />of the proposed 2017 topsoil stripping parcel depicted on Map M l OB. Please review the topsoil <br />stripping plan and replacement plan depicted on the proposed M l OB map and reconcile it with <br />what has occurred to date and what Trapper plans in 2016 and 2017. <br />Trapper Response: Please see the prior comments concerning variability in stripping limits <br />within the permit term. <br />Based on the item above, please review Table 3.1-3 on proposed revised page 3-13 and make <br />any necessary updates to the topsoil replacement balance for the permit term. <br />Trapper Response: Table 3.1-3 has been revised and is included. Changes that reflect <br />Trapper Mine's plans for 2016 and 2017 are shown in the table. This table has been <br />updated to include the actual disturbance and Reclamation for the years 2013-2015 and <br />projected disturbance and reclamation for 2016 and 2017. <br />Please evaluate the topsoil balance for the KLM pit and demonstrate in detail if the cost <br />estimate shown on Table A-10.6 is still adequate. Or, if necessary, please update this table with a <br />new cost associated with topsoil replacement of the KLM pit. <br />Trapper Response: Attached is table A-10.6 showing an additional 154.0 acres of topsoil <br />replacement. The cost for this material was updated using D.R.M.S. unit costs <br />information from the Circes Estimate generated on April 20, 2015. This data was <br />inserted beneath the Table A-10.6 and the additional costs were added to the topsoil <br />summary (Table A-9). The 154.0 acre number was determined by subtracting out the <br />original 204.2 acres of lap need reclamation in 2013 from the original estimated "Open <br />Acres ", and adding back in what was not actually reclaimed (52.2 acres). Then adding <br />the 101.8 acres of actual + proposed disturbance through 2017.The summary below <br />represents the process utilized in estimating the additional area of disturbance: <br />