2013-07-29_REVISION - C1981010 (3)

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Trapper Mining, Inc. C- 1981 -010; PR7 Adequacy Review No. 1 Page 5 of 7 ii. Freeboard shall be no less than 0.3 feet. Please provide details on the proposed channel dimensions so that the Division can determine whether the designed channels maintain the required freeboard. Trapper must submit the information required in Items (a) through (c) for all postmining drainage channels to be constructed, completed, or reconstructed during the current permit term. 24. Trapper did not submit designs for the three proposed sediment ponds that are shown east of the current disturbance boundary, as required by Rules 2.05.3(4) 4.05.5, 4.05.6, and 4.05.9. Prior to any surface disturbance east of the Deal, Middle, East Flume, and East Middle Flume watersheds, Trapper must obtain approval for and construct appropriate sediment control for all areas proposed to be disturbed. Trapper will need to provide the required design information for sediment control measures to be used for proposed disturbance east of Deal, Middle, East Flume, and East Middle Flume watersheds. There is currently a stipulation in place to this effect from Permit Renewal No. 6. Trapper should be aware that prior to any disturbance in the expansion area, including the construction of sediment control facilities, the baseline information required from Rule 2.04; as discusses above, must be submitted and approved by the Division. Appendix A, Bond Estimate: The Division has reviewed the cost estimate submitted and it appears to account for the worst case disturbance for the next permit term. However, the estimate does not appear to take into account disturbance areas that have not been bond released. The Division cannot release liability associated with disturbed areas through the permit revision process. 25. The cost estimate provided by Trapper is broken up into reclamation tasks generally associated with a particular pit area (Ash Pit, D/E Pit, K/Gd Pit etc.). The Division could not locate a specific map which depicts the boundaries of these pit areas and their associated disturbance. Given this, it is difficult to verify disturbance acreages for a given pit. Since these pits designations are cited throughout the permit and used for cost estimate, please submit a map which depicts the disturbance area and the boundaries of each of designated pit areas. 26. In addition to item 20 above, it may also be helpful to include an additional table in the bonding section which lists each of the pit areas and their associated total disturbed acreages and the acreages that have been Phase I, II and III bond released. 27. The cost estimate for regarding the Ash Pit does not include portions of Parcels A -13-10 and A -13-12 which have not received Phase I bond release. The Division cannot release liability associated with backfilling and grading through the permit revision. Given this, please revise the cost estimate associated with the Ash pit disturbance to account for the pit area that has not been granted Phase I bond release. 28. The current cost estimate includes a cost for re- grading the F -Pit. This cost appears to be based on volumes derived from cross sections submitted and associated with PR6 and the current Map M6. Portions of the F- Pit area associated with the current reclamation cost has not been Phase I bond released. The Division cannot release liability associated with backfilling and grading through the permit revision. Given this, please revise the cost estimate associated with F Pit to account for the pit area that has not been granted Phase I bond release. 29. The current cost estimate includes a cost for re- grading the Z dip -Pit. This cost appears to be based on volumes derived from cross sections submitted and associated with PR6 and the current Map M6. The Z