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Division's initial comments No. 2: Please include the area disturbed by the October 8, 2006, <br />East Panel landslide as "disturbed area". Please provide a reclamation plan for the slide area <br />and reclamation costs associated with reclamation of the slide area. <br />Trapper Mining Inc. 's initial response: Trapper Mining Inc. provided a description of the <br />process in which reclamation would be conducted on the East Panel slide in the event that the <br />area is not developed for mining. Trapper Mining Inc. provided reclamation cost estimates for <br />tasks associated with the reclaiming of this area. <br />Division's response: The Division calculated reclamation costs for tasks associated with the <br />reclaiming of the East Panel slide area. In the Division's estimate, the new tasks are identified <br />as Task numbers 08a, 09a, 09b, 09c, 09d, 108, 113, 115 and 179. Task 114 provides <br />reclamation costs for the sealing of development drill holes (exploration holes conducted within <br />the permit area and not permitted under an exploration permit). <br />The Division utilized volumes provided by Trapper Mining Inc. and found them to be <br />supported. However, an explanation of where the topsoil for placement on the East Panel <br />landslide area will be hauled from was not included. The Division's Task No. 179 used the <br />haul distance provided by Trapper Mining Inc. <br />Please provide additional explanation to address where the topsoil utilized for placement <br />on the East Panel landslide area will be hauled from. <br />Division's initial comment No. 3: Trapper Mining Inc. provided development drill hole sealing <br />reports on February 27, 2002 (76 holes), Apri14, 2005 (74 holes), and November 23, 2005 (29 <br />holes). The reports provide drill hole location, drill hole depth, and sealant volume and stated <br />that the holes had been sealed in accordance with permit section 3.3.2. These holes are <br />included within Trapper Mining Inc.'s development drilling program as described in permit <br />section 3.3.1. No reclamation costs have been assigned with sealing of these holes. The <br />majority of the holes are expected to be mined through within the following year. However, <br />there exists the potential for the Trapper Mine plan to be revised and drill holes to not be mined <br />through. Currently the Division retains no bond monies assigned to sealing of development <br />drill holes per Rule 3.05. The Division maintains that a cost for sealing of the development <br />drill holes needs to be accounted for in the reclamation cost estimate. One approach would be <br />to include a sealing task for the projected annual anticipated development drill holes, provide <br />annual sealing or mined through updates with Annual Reclamation Reports along with the <br />projected number of holes anticipated for the following year. Please add costs for annual <br />development drill hole sealing into the reclamation cost estimate per Rule 3.05. <br />Trapper Mining Inc. 's initial response: Trapper Mining Inc. has provided an estimate for <br />"worst case" sealing of exploration holes. Trapper Mining Inc. estimated that there could be 75 <br />exploration holes, each 170' deep and assume 6" in diameter. <br />Division's response: The Division's Task 112, dated 11/28/2007, derived a cost of $16,390 <br />for 16 boreholes, 170' deep at 6" diameter. The Division's new Task 114 derived a cost of <br />$77, 531 for the sealing of 75 development drill holes using the same basis for sealing holes <br />