2020-07-17_REVISION - C1981010 (3)

Home Browse Search

Mr. Forrest Luke Page 3 of 7 July 2020 Rule 2.03.10 Identification of Other Liscenses and Permits DRMS July 2020 This was address in the preliminary round of adequacy questions and may have changed since then. 1. Please inform DRMS if there have been any changes as per the above mentioned rule. Rule 2.06.5 (e) Variance from Approximate Original Contour DRMS July 2020 In reviewing the cross sections for the Ash Pit, DRMS finds that NE Section proposes a maximum post mine surface of 175 feet higher than the premine surface. At the NW Section generally a postmine surface of approximately 100 feet higher is proposed. In reviewing the cross sections for the D Pit,DRMS finds that post mining topography ranges from 60 feet to approximately 100 feet lower than the preming topography creating a drainage corridor. Pre and post mine topography converge at both the northern and southern ends of the D pit. In reviewing the cross sections for the L Pit,DRMS finds that post mining topography ranges from 80 feet to 175 feet lower than the preming topography. Rule 3.02.2 Performance Bond Determination DRMS July 2020 DRMS is unclear as to exactly what acreage represents the net increase in affected for PR9 given the permitting actions submitted since the 2018 submission of the PR9 application. The original application requested of 2018 requested 564 acres of disturbance. Table 3.1-3 indicates 3121.8 acres as projected disturbed acres for the end of the permit term in 2022 taking into account Phase III bond released acres at the end of 2017. This value appears to represent open acres, and reclaimed acres. TMI's table 1.4-1 in Appendix A utilizes 1584.6 acres for the PR9 worst case bond. Utilizing TMI's information this value appears to represent a summation of the open acres at the beginning of the permit term,topsoil removal and final regrade. Understanding that table 3.1-3 represents projected acres DRMS is unclear about this basis. DRMS records indicate the disturbed acreage at 3,326.3 and must hold bond for all affected land. Also, TMI's numbers in the PR9 bond calculations do not corroborate the acres submitted in TMI's Annual Reclamation Report and this document may be a more accurate representation of acreages for utilization in bonding calculations. Also, since PR9 has been submitted, a number of TRs and MRs have been submitted changing the affected area and some of those approvals may overlap what was originally proposed with PR9.