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Trapper Response to Comment 31: The total existing permit area for Trapper Mine is 11,160.83 acres. The PR-II <br /> expansion is for an additional 137.1 acres.The new total permit area should be 11,2978.93 acres. This is based on <br /> the legal description within the Trapper Mine permit(page 1-68). This acreage may be more or less.The DRMS <br /> permit system shows this acreage at 11,157.0 acres in the application form for PR-11,the addition of the 137.1 acres <br /> of new permit area gave a value of 11,294.10. I am unsure why there is a discrepancy. <br /> The affected of acreage of Trapper mine will increase by 578.5acres which includes 295.0 acres of requested new <br /> surface disturbance and an additional 283.5 acres of highwall miner panels under undisturbed and Phase III bond <br /> released lands. <br /> The disturbed area will increase by 295.0 acres of requested new surface disturbance for pit advancement not <br /> already approved by other revision actions. The acres reclaimed and not yet bond released have been calculated <br /> from the proposed 2022 ARR values. The ARR calculations show that 885.8 acres of reclamation are currently <br /> present at the site that have not attained any level of bond release. The approval of SL-23 in January 2022 is <br /> included in this calculation. The calculations for the bonding cost of RNYBR,based on Trapper's App. A are <br /> attached as attachment 1 to this letter for the Divisions'reference in their own final calculation. Trapper will have <br /> forthcoming comments on the draft CIRCES run. <br /> Trappers' response adequately addresses the above cited question. DRMS notes a typo,highlighted <br /> in yellow and understands that 11,294.10 acres represents the correct value. <br /> Rule 4.05.6 and 4.05.9 Sediment Ponds <br /> DRMS 28 February 2023 <br /> DRMS's understands that in East and West Buzzard drainages additional ponds are proposed <br /> (one in each drainage), and additional NPDES monitoring points are proposed. <br /> DRMS finds that the SEDCAD modelling provided with the PR11 submission to be accurate <br /> with the exception of: <br /> 32. Stage storage curves do not track the Capacity Table as output in the modelling. <br /> Trapper Response to Comment 32: A review of the East and West Buzzard SEDCAD modeling by Trapper <br /> personnel and a SEDCAD consultant found no concerns with the comparison between the stage storage curves and <br /> capacity tables. Confusion may be related to the elevation-capacity-discharge table beginning at 0 at the top of the <br /> 60%sediment clean out level. Modeling for the capacity table begins at this elevation rather than the bottom of the <br /> pond as given in the stage storage curve. <br /> Trappers' response adequately addresses the above cited rule. <br /> Rule 4.05.13 Surface and Groundwater Monitoring <br /> DRMS 28 February 2023 <br /> Trapper Mine has a robust surface and groundwater monitoring program as outlined in Sections <br /> 4.8.5.1 and 4.8.5.2 of the permit. Revised pages regarding surface water sampling, water quality <br /> updates, groundwater data and the additional sampling sites in the PR11 expansion area <br /> adequately address this rule with the exception of: <br /> 33. Well P8 is indicated in the PRll submission to be sampling the 2nd White Sandstone, <br /> while the current permit page shows Well P8 to be drilled in the 3rd white sandstone. <br /> Please clarify. <br /> Trapper Response to Comment 33: Trapper corrected the discrepancy on the revised and enclosed <br /> Table 2.7-20 to change the 2nd White Sandstone designation to the correct Third White Sandstone <br /> designation. <br /> 13 <br /> Trapper Mine PR I ADQ No 2 <br /> 2023 February <br />