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Midterm or Renewal actions. <br />Additional Midterm Review Items <br />The Division reviewed another item that has no specific requirement in the Regulations requiring <br />their review. Regarding the timing of backfilling and grading (Rule 4.14.1), TMI has been granted <br />a variance from the requirement that this operation be performed within 180 days after coal <br />removal. This variance was granted in the approval of a permit revision in 1.988 (PR-02). <br />Regarding the D/E Pit, which has been temporarily abandoned and left open for an extended period <br />of time, a plan to use this pit for utility waste disposal (ash from the Craig Power Plant) has been <br />approved (as discussed in PR-02). <br />Bond <br />The Division has reviewed the reclamation cost liability for the Trapper Mine permit. The <br />reclamation cost liability is estimated as $31,127,989.00. This amount is sufficient to assure <br />completion of the remaining reclamation work at the site if the work had to be performed by the <br />Division, including the cost of reestablishing vegetation on any revegetated areas, should those <br />areas fail. The permittee currently has on deposit with the Division a corporate surety bond in the <br />amount of $30,173,724.00, based on-the most recent bond rider increase. Trapper Mining Inc. <br />needs to submit an additional rider to bring surety bond into agreement with the estimated <br />reclamation cost. <br />A copy of the Division's estimate is included with this Midterm Review document. <br />PART III - REQUESTED REVISIONS OF PERMIT APPLICATION <br />The Division requests that staff at Trapper Mining, Inc. determine if the following items are up-to- <br />date in the permit application binders: <br />• Names, addresses, and other contact information for the entities and individuals listed in <br />Section 1.2, including (but not limited to) agents, officers, and directors. <br />• Information on other permits in Tables 1.2-1 and 1.2-2. <br />• The status of the Threatened and Endangered Species list of the U.S. Fish and Wildlife <br />Service and the Colorado Division of Wildlife and how this relates -to Trapper Mine. <br />If any of these items are not up-to-date, the permit must be revised accordingly. Furthermore, <br />please resolve any discrepancies between the latest renewal application (RN-05) and the 2009 <br />ARR. <br />Based on the current Midterm Review, the Division finds that permit application C-81-010 <br />Trapper Midterm 2010 Findings.REV 3.docx Page 5