2020-10-23_INSPECTION - C1981010 (3)

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Township 6 North, Range 91 West of the 6th PM: • Portions of Sections 35 and 36 Notification of the proposed Phase I bond release was posted in the Craig Press for four consecutive weeks beginning July 10, 2020 and ending July 31, 2020. Notification of the proposed Phase II bond release was posted in the Craig Press for four consecutive weeks beginning August 7, 2020 and ending August 28, 2020. The parcels proposed for Phase I bond release were reclaimed between 2017 and 2019; Phase 11 parcels were reclaimed between 2014 and 2016. TMI currently posts a surety bond in the amount of $30,500,000 which covers the entire mine site including the above listed areas. TMI is not requesting any reduction in the bond amounts held for the SL-21 or SL-22 parcels. Colorado outlines the requirements for bond release at Rule 3.03.1 of the Regulations for the Colorado Mined Land Reclamation Board. For Phase I up to 60% of the applicable bond amount shall be released when the permittee successfully completes backfilling, regrading (which may include the replacement of topsoil and seeding), and drainage control in accordance with the approved reclamation plan. For Phase 11 up to 85% of the applicable bond amount shall be released upon the establishment of vegetation which supports the approved postmining land use and which meets the approved success standard for cover, based on statistically valid data collected during a single year of the liability period. Findings The Team walked each reclamation parcel below to visually confirm the applicable performance standards for bond release had been met. Phase I • L-AB-18 (57.6 acres) • L-AB-19 (117.8 acres) • Z-A-17 (44.0 acres) • F-B-19 (78.9 acres) No issues were noted that would prevent partial Phase I bond release on the 298.3 acres as applied for under SL-21. The parcels were stable and free of major erosional features. No slumps, pits, or remaining highwall was observed. The post -mining topography was representative of and blended well with the undisturbed surroundings. A DRMS inspector collected random elevation readings across each Phase I parcel for comparison to pre -mining topography. Drainage control had been re-established in accordance with the approved Trapper permit which calls for a combination of vegetation and rock drop structures within reconstructed channels to manage hydrologic velocity. The Team remarked at the difference only one or two growing seasons had made in terms of vegetative establishment and maturation: while the parcels reclaimed in 2019 (L-AB-19 and F-B- 19) had noticeable quantities of weedy annuals such as kochia, field pennycress, and tumble mustard, the 2018 parcel (L-AB-18) contained significantly less, and in the 2017 parcel (Z-A-17) desirable perennials such as basin wildrye, western wheatgrass, fescue, sagebrush, yarrow, cicer 2 1 P a g e