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Tabetha Lynch, DRMS <br />Page 2 <br />June 17, 2016 <br /> <br />o Trapper’s Response: Trapper updated the table as requested, however they <br />updated their projected reclamation for 2016 and 2017 to show that zero acres <br />will be reclaimed for the remainder of the permit term. <br />o Division Response: Historically, the mining/regrade and topsoil <br />stripping/replacement has been more flexible at the Trapper Mine. However, this <br />flexibility presents a problem when it comes to insuring the worst case bond <br />disturbance has not been breached. Rule 2.05.3(2)(a) and 2.05.4(2)(a) requires a <br />detailed timetable sufficient to describe the various mining phases proposed and <br />a detailed timetable for the completion of each major step in the reclamation <br />plan. Table 3.1-3 contributes to meeting the requirements of these rules and <br />assists in verifying the worst case disturbance projection as well as a tool for the <br />Division to use to verify the worst case disturbance has not been exceeded and <br />thus the site becoming under-bonded. There is a significant change in the <br />number of acres proposed to be regraded, topsoiled and seeded between what <br />Trapper is requesting with TR115 and what is approved currently. Based on <br />proposed revised table 3.1-3, TMI no longer projects to regrade, topsoil and seed <br />105 and 102 acres in 2016 and 2017 respectively. In order to continue to qualify <br />for a “rolling bond”, backfilling, grading, topsoiling and seeding must be done <br />concurrently with mining. This issue was discussed with Graham Roberts with <br />TMI on June 15th, 2016. According to Graham, Trapper does intend to conduct <br />reclamation in 2016 and 2017 but they had removed the acres they projected to <br />reclaim in 2016 and 2017 for reasons that are not exactly clear to me. In <br />summary it was discussed with Graham that Table 3.1-3 will need to be revised <br />to show the projected reclamation in 2016 and 2017. It was agreed that Table <br />3.1-3 should be revised to show what reclamation was completed in 2013, 2014 <br />and 2015 and to project what will be reclaimed in 2016 and 2017. Given this, I <br />offer the following response to TMI’s response to the adequacy review item: <br /> Table 3.1-3 will need to be revised to show the projected reclamation in <br />2016 and 2017. It was agreed to by TMI and the Division that Table 3.1- <br />3 should be revised to show what reclamation was completed in 2013, <br />2014 and 2015 and to project what will be backfilled and graded in 2016 <br />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 <br />table with a new cost associated with topsoil replacement of the KLM pit. <br />o Trapper’s Response: TMI provided a demonstration that the number of acres <br />originally bonded for in the KLM pit would need to be increased with the <br />approval of TR115 and provided an estimate of the additional acres to be bonded <br />as well as cost estimate for the activity. A copy of Table A-10.6 was provided in <br />the cover letter but Trapper did not submit an updated table for Appendix A.