2020-10-15_REVISION - C1981010

• Permit No: C1981010
• IBM Index Class Name: Revision
• Doc Date: 10/15/2020
• Doc Name: Adequacy Review Response #2
• From: Trapper Mining Inc
• To: DRMS
• Type & Sequence: PR10
• Email Name: JLE
• Email Name: RAR
• Media Type: D
• Archive: No

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3. Please clarify andjustify the cost estimate submitted with the application.
Trapper Response:
The overburden removal/mining sequence in I and Jpits utilizes the waste material from one pit to
backfilled into another pit. The waste material from the initial pit must be placed in an out ofpit
spoil dump. Spoil material from subsequent pits is hauled back to the prior mined out pit. This
results in the prior pit being backfilled as the new pit is being developed. Therefore the
assumption was made that before the Worst -Case Bond Year occurs, most of the I and Jpit
complex would be backfilled, topsoiled and revegetated to the Worst -Case Bond Year of 2022.
2020
2021
2022
Total
Acres
Acres
Acres
Acres
Disturbed Acres
I Pit Middle
31.9
31.9
I Pit East
37.7
37.7
J Pit Middle
56.5
56.5
J Pit East
28.4
51.5
79.9
08 Pile
0.9
0.9
Total Disturbed
61.1
145.6
206.7
Reclaimed Acres
I Pit Middle
31.9
31.9
1 Pit East
23.4
23.4
J Pit Middle
56.5
S6.5
J Pit East
14.2
14.2
Total Reclaimed
31.9
94.1
126.0
Net Open Acres
61.1
174.8
80.7
The table above anticipates having 80.7 acres of open lands at the end of the permit term that
ultimately needs to be reclaimed. It is anticipated that there will be 126 acres of reclaimed land
that will not be Phase Bond Released as yet. Trapper submitted the PR10 application prior to
the final approval of the PR9 application, in which corrections were made regarding this
assumption that, lands assumed to be graded topsoiled and revegetated, prior to the Worst Case
Bond Year would require additional work, (see CIRCES Task RNYBR). Utilizing this premise,
the Bond Estimate for PR10 has been revise to include these 126.0 acres in I and Jpits. A
separate tasklline item was inserted into the Direct Cost portion of the PR10 Appendix A
Summary Table (Table A-1), which includes the additional costs of topsoil placement and
revegetation for the entire 206.7 acres, 80.7 acres to be fully reclaimed and 126.0 acres of
RNYBR. The same unit costs and methodology used for CIRCES PR9 bond RNYBR
adjustment was also employed in the PR10 cost adjustment. The revise PR10 bond estimate is
included.
DRMS October 2020
Trapper's response is adequate with the exception of:
3a. Please submit Table 1.4-1 Open Acreage Table as part of this permitting action.
Trapper Response:
Upon further discussion with Ms. Reilley updates to table 1.4-1 will not be necessary. The requested
information has been included on the "Appendix A Bond Addendum Summary," with the additional
bonding amount added for PR-10 and included in this response.