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Mr. Forrest Luke <br /> Page 4 of 7 <br /> July 2020 <br /> 2. Given the approved MR's and TR's since the PR9 application, DRMS would like <br /> documentation from TMI demonstrating that the net increase in affected land does not <br /> exceed the originally proposed 564 acres. <br /> 3. As the worst case bonding scenario should represent the affected land DRMS is approving <br /> in the PR9 permitting action, please provide DRMS with acreage representing the net <br /> increase in affected area. <br /> DRMS has included the CIRCES cost estimate with this review. Table 1 below shows DRMS's <br /> calculation of the worst case bond estimate when applying the costs of reclamation for Phase I and <br /> Phase II areas. <br /> Table 1: Worst Case Scenario <br /> Acres* Cost/Acre % <br /> PR9 Worst Case Bond Estimate Total $31,595,465.00 1584.6 $19,939.08 100% Phase Bond Release Acreage <br /> Phase I Bond Release $1,367,023.27 171.4 $7,975.63 40% Phase 4386.2 <br /> Phase B Bond Release $1,567,809.80 524.2 $2,990.86 15% Phase 2 4214.8 <br /> *Reg Acres 1584.6 Acres as per Trapper table 1.4-1 Phase 3 3690.6 <br /> PR9 Cost Total(REQ Surety) $34,530,298.08 <br /> Acres* as per trappers Table 1.4-1 <br /> DRMS understands that TMI's permit provides for a maximum of 200 development drill holes. <br /> However, TMI's bonding proposal bonds for 20 development drill holes. <br /> 4. Please either update the permit section 3.3 or update the bonding in Appendix A for the <br /> PR9 permitting action. <br /> Rule 4.27.4 Operation on Steep Slopes <br /> DRMS July 2020 <br /> DRMS notes that a concurrence letter,dated I July 2020 was received from the State Land Board as <br /> the owner of record for portions of the Ash Pit. This letter accepted the AOC variance proposed by <br /> Trapper Mine. The Land Board distributed the letter to DRMS, Trapper Mine and the Land Board <br /> Minerals Director. <br /> The above mentioned rule is adequately met. <br /> Rule 4.14 Backfill and Grading <br /> DRMS June 2020 <br /> During a Division pre-site visit and inspection in November of 2018, it was observed that the <br /> A-pit is partially filled with compacted ash material. However,there was no discussion or <br /> inclusion of this material in the stability analysis. <br /> 5. Please provide the Division with additional discussion about the ash material found in <br />