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C1982056, RN5, Adequacy Review 5 1/16/2009 <br />TC has provided documentation in the form of agreements with the one and only domestic water <br />user downstream on Trout Creek and it is the Division's understanding that based on this <br />agreement, there are no water users on either of these segments downstream of TCC mine water <br />discharge for domestic purposes. Therefore, the Division believes that a sulfate standard does <br />not limit TLC's volume or quality of mine discharge. However, other stream standards do apply <br />as shown in the tables for other constituents. The Division finds that it is appropriate for TCC to <br />review that section of the permit that deals with discharge limits imposed on TCC based on <br />conductivity and sulfate ratios, and propose revisions based upon the this updated information. <br />18. Due to concurrent permitting action that occurred recently. There appears that there is more <br />than one version of Map 24. Please make sure that all the revisions that were approved are <br />included on one version of Map 24. It appears that there is not one version of map 24 that <br />incorporates changes approved during MR61, MR222, and MR228. Please review the most <br />recently approved version of Map 24 and assure that all previously approved changes are <br />included. <br />19. On page 2.04-42 "Known uses of Ground Water", the text refers to "Exhibit 6H, Summary of <br />Ground Water Rights". This is an incorrect reference. Exhibit 6H is "Class III Cultural <br />Resources Inventory". Please correct the reference to direct the reader to the appropriate <br />location for Groundwater Rights. <br />20. RCE= $7,832,530.89. TCC's response to Adequacy questions Nos. 1 and 2 will require <br />revision to task no. 069, which will result in a change to the Reclamation-Cost Estimate total. <br />Please find copies of the Division's estimate attached to this letter. <br />The Division currently holds two bonds that total $7,933,169.00. The required liability upon the <br />approval of MR233 (December 15, 2008) was $7,875,818.84. The updated estimate represents a <br />reduction of $43,287.95, or -0.5%. <br />Revisions approved since that last RCE (MT2005) have been incorporated into the RN5 RCE. <br />TCC has not requested bond release for any tasks. Although fuel costs and operating costs have <br />increased as reflected in increased costs for many of the tasks, some costs have decreased. Well <br />sealing costs have gone down due, in part, to the method the Division is using to conduct the <br />well sealing estimate task. The Division currently estimates the volume of the void space to fill, <br />then calculates the cost of the volume of cement grout required to fill the void, and the hours <br />necessary for a crew and equipment to seal. Previously the sealing tasks used an industry <br />standard reference (R.S. Means) which used different sized crew costs for sealing tasks. The <br />Division believes the current method of estimating sealing costs more closely represents actual <br />sealing costs. <br />Some tasks that previously may have been estimated individually have been combined together <br />where logical. Other updates to the RCE include eliminating rippers on dozers if not needed for <br />the task, elimination of dump area support equipment if not warranted for a specific task, <br />elimination of unintentionally duplicated tasks, consolidation of seeding tasks where logical, <br />logical corrections to haul distances, and consolidation of mobilization and demobilization tasks.