2013-07-29_REVISION - C1981010 (3)

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Trapper Mining, Inc. C- 1981 -010; PR7 Adequacy Review No. 1 Page 6 of 7 dip -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 Z -dip Pit to account for the pit area that has not been granted Phase I bond release. 30. The current cost estimate for the AE Pit is based on backfilling 879,238 cubic yards of material. The new estimate is based on a cost for backfilling 471,746 cubic yards of material. This is 407,492 cubic yards less than the current estimate. It does not appear area within AE Pit has been granted Phase I bond release. Please explain this large decrease in volume needed to backfill this pit. 31. The current cost estimate for the K and G Pits are based on backfilling 3,799,225 cubic yards of material. The new estimate is based on a cost for backfilling 2,169,306 cubic yards of material. This is 1,629,919 cubic yards less than the current estimate. It does not appear areas within K/G Pits has been granted Phase I bond release and it appears the majority of the projected worst case disturbance used to calculate the current backfill volume amount has occurred. Given that Phase I bond release has not been approved for K/G pit disturbance please explain this large decrease in volume needed to backfill this pit. 32. The current cost estimate includes a cost for drilling and blasting the F Pit, Z -Pit, East A Pit and K -Pit. The proposed estimate only includes a cost to drill and blast the highwall associated with K/G Pit. Given that Phase I bond release has not occurred for the areas currently bonded for F Pit, Z Pit and East A Pit and that disturbance did occur in these areas, the proposed cost estimate needs to include a drilling and blasting the highwalls in F, Z and east A pit. Please revise the cost estimate to include this cost. 33. The current cost estimate in a cost to regrade the K -Pit using a truck/shovel team. Table 1.4 -2 in the current permit indicates the volume of material necessary to move for this task is 5,644,528 cubic yards. The proposed table A -4.4 indicates only 2,818,014 cubic yards of material is necessary to complete this task. This is a reduction of 2,826,514 yards. It does not appear that K -Pit parcels have received Phase I bond release. Give this; please explain this significant reduction in material volume. 34. Deal Pond is required to be reclaimed. Please update Table A -7.1 and Table A -7.2 to account for the Deal Pond regrade costs. 35. The Division's copy of the revision is missing the Talpac results for stockpile A96 -1A. The Division needs the road haul segment grade and length in order to complete the cost estimate. 36. The demolition cost estimate provided in Appendix A, Table A -12.1 is missing the cost to demolish the Carpenter Shop. Please update the estimate to account for this cost. 37. Proposed Table A -13.6 provides a cost to seal the landslide monitoring stations. This table only provides a cost for monitoring stations 7 and 8. Two additional stations are included in the monitoring program as discussed on revised page 3 -27b; stations 5 and 6. Please update this table to include the cost to seal these two monitoring stations. 38. It is difficult to verify and complete the cost estimate for topsoiling and revegetating certain pit areas for the reasons discussed in Items 25 and 26 above. The Division cannot release liability for disturbance that has occurred but has not been phase bond released. Please verify the volumes and acreages for each topsoiling and revegetation task associated with each pit disturbance to insure that for each pit area there is enough cost to cover the worst case disturbance for this permit term and acreages that have not been bond released.