2023-02-03_REVISION - C1981010 (4)

Home Browse Search

The following are the Division's responses associated to Trapper's comments from their letter dated January 26,2023. Excerpts have been pulled from this letter(italicized)in hopes to provide a clear response to all comments or questions provided by Trapper. ■ Trapper: Attachment I to this correspondence is a revised RNYBR calculation taking into effect the actual acres on the site that are not in some form of bond release status. The CIRCES estimate contains retained surety for the acres of Phase I and Phase II bond release present on the site at this time. The RNYBR calculation is intended to preserve additional surety for areas of the site that are not reclaimed fully, or in various stages of reclamation, but not within these Phase I and Phase II bond release acreages. The other remaining acreage of the site is contained within the WCB scenario calculations and surety is held for the regrade, topsoil and seeding of these acreages. In this case, PR-11 calculates WCB for approximately 2,307 acres, 885 acres exist on the site that are reclaimed, but not Phase III bond released. OF these 885 acres, approximately 295 are Phase I released and 433 are Phase II released. Trapper has calculated extra surety should only be held on approximately 120 of the remaining acres of reclamation on the site, not the full 885 as inferred in the adequacy comments letter of January 20th. When calculating Trapper's RNYBR costs,the Division does not include the acreages which have received Phase I and Phase II bond release in the Worse Case Bond(WCB).Using the WCB liability amount,the Division calculates a cost per acre based on total disturbed acreage that has not achieved bond release (including new disturbed acreage proposed with PR-11). This cost per acre is then applied to the acreage associated with achieved Phase I and Phase II bond release along with the percentage remaining for the associated Phase release.The total new site wide liability is then the WCB liability plus the calculated Phase I and II liability.The Division has renamed the table found on the first page of the Division's RCE to hopefully avoid confusion. For additional clarification and transparency,the Division has included Appendix 1 at the end of this memo summarizing the steps in how the Division calculates costs for Trapper's RNYBR acreages. It should be noted that the costs have changed from the Division's previously provided RCE which can be summarized from a change in the WCB calculated based on updates to the Division's RCE(see below for more details) and a change in acreages reported from Trapper's 2021 ARR to 2022 ARR. ■ Trapper: With respect to the BackFll& Grading, the following observations were made: • In L Pit, two cross-section quantities were removed from the truck/excavator volumes late in the PRII Bond Estimate process. o Cross-Section 402,200 (463,296 cy)plus Cross-Section 402,700 (399,981 cy); a total of 863,277 cy were removed from the TIE volume for L Pit. o Although the volumes were removed from Table A-4.6A, the costs inadvertently remained, which resulted in$604,211.32 that should not have been present. o This reduced the Truck/Excavator costs in L Pit from the reported$1,748,356.16 amount to$1,144,144.84 that should have been reported for this task(L15). o The reported volume of 1,647,275 cy was correct, but the costs were in error in the submitted App.A. Trapper Mine RCE Memo February 3,2022