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COLORADO <br /> Division of Reclamation, <br /> A C10- 0 Mining and Safety <br /> Department of Natural Resources <br /> June 17, 2020 <br /> Jim Stover,P.E. <br /> J.E. Stover&Associates,Inc. <br /> 2352 North 7tt'Street, Unit B <br /> Grand Junction, CO 81501 <br /> Re: North Thompson Creek Mine,Permit C-1981-025, <br /> Review of the 2019 ARR <br /> Dear Mr. Stover: <br /> The Division received the 2019 Annual Reclamation Report(ARR) for the North Thompson Creek Mine on <br /> January 10,2020. I have the following comments and questions regarding the ARR form within the report. <br /> 1. Please explain the difference between total disturbed acres (65.9 ac) and the total backfilled and graded <br /> acres(65.2 ac). What area constitutes this 0.7 acre difference? <br /> 2. For an underground mine,the total disturbed acreage should equal the sum of backfilled and graded acreage <br /> plus permanent facilities acreage. (There can be exceptions if there are areas that were topsoiled and/or <br /> seeded that did not require back filling or grading.) Why do the values in the ARR form not meet this rule? <br /> If one adds the backfilled and graded value (65.2 acres) to the permanent facilities value (4.8 acres), the <br /> sum is not equal to the total disturbed value(65.9 acres). <br /> 3. In the Acres Seeded section of the form, the acreages that have been Phase III released should not be <br /> omitted. <br /> 4. Also in the Acres Seeded section,do the pond areas(developed Water Resources)constitute the 4.8 acres? <br /> If so,were these areas in fact seeded? Perhaps part of the 4.8 acres was seeded(e.g.,to vegetate dams)? <br /> 5. In the Bond Release section of the form, the area that has been Phase I and II released but not Phase III <br /> released appears to be 4.1 acres. Why is that value smaller than the acreage for permanent facilities (4.8 <br /> acres)? Should those values be the same? <br /> Please call or e-mail me with any questions related to this review,or submit a formal response(including a <br /> revised ARR form,if necessary)via the Division's ePermitting system. <br /> Thank you, <br /> V4--' / . 7' <br /> Robert D.Zuber,P.E. <br /> Environmental Protection Specialist II <br /> Cc via email: Gina Roybal, S&B Holdings,LLC <br /> of CO<o <br /> y ' <br /> 1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.Co.us I <br /> Jared S. Polis, Governor I Dan Gibbs, Executive Director I Virginia Brannon, Director **1 * <br />