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Additional Midterm Review Items <br />The Division reviewed another item that has no specific requirement in the Regulations <br />requiring their review. Regarding the timing of backfilling and grading (Rule 4.14.1), TMI has <br />been granted a variance from the requirement that this operation be performed within 180 days <br />after coal removal. This variance was granted in the approval of a permit revision in 1988 <br />(PR-02). <br />Regarding the D/E Pit, which has been temporarily abandoned and left open for an extended <br />period of time, a plan to use this pit for utility waste disposal (ash from the Craig Power Plant) <br />has been approved (as discussed in PR-02). TMI is proposing a revision to the post mine <br />topography of the D/E pit with PR9 based on projected future reductions of coal ash placement <br />as a result of known and probable future Craig Station unit closures. At the writing of this <br />document, PR9 is currently under review by DRMS. <br />Bond <br />DRMS is currently reviewing PR9 which updates the projected liability amount for the permit <br />term. The PR9 cost estimate will update the site -wide estimate for the reclamation liability at <br />the site based on the revised operation and reclamation plan. DRMS projects issuing a <br />decision on PR9 on June 30, 2020, however this is subject to change. With the approval and <br />issuance of TR124 on May 19, 2020, DRMS increased TMI's liability for the Trapper Mine by <br />$8,106,155.00. Also, with the approval of SL20 on May 20, 2020, DRMS evaluated the <br />reclamation liability at the site and found the current required surety of $29,491,874.54 to be <br />sufficient to complete reclamation of the affected land. The Division currently holds a <br />corporate surety of $30,500,000.00 for the Trapper Mine. <br />SECTION III - REQUESTED REVISIONS OF PERMIT APPLICATION and <br />MIDTERM ADEQUACY QUESTIONS <br />As a result of this midterm review, for the purpose of fulfilling the requirements of the <br />Colorado Surface Coal Mining Reclamation Act, and the Regulations of the Colorado Mined <br />Land Reclamation Board for Coal Mining, pursuant to Rule 2.08.3, the Division finds that the <br />permit application C-1981-010 contains the below bulleted deficiencies. The Division requests <br />that the permittee correct the deficiencies by submission of revised permit pages under <br />appropriate revision applications, by September 30, 2020. <br />The Division recognizes that sections of the permit are currently being revised by PR9. <br />2.03.4 Identification of Interest <br />• If PR9 is not issued, TMI will need to update the applicable information in Section 1 of <br />the permit binder. <br />2.04.7 Hydrology Description <br />MT8_Trapper Midterm 2020 Findings JLE (1) Page 7 <br />