2013-10-29_REVISION - C1981010 - Laserfiche WebLink

Home Browse Search

STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 C O L O RA D O D I V I S I O N o f Denver, Colorado 80203 RECLAMATION Phone: (303) 866 -3567 M I N I N G FAX: (303) 832 -8106 SAFETY October 29, 2013 John W. Hickenlooper Governor Forrest Luke Trapper Mining, Inc. Mike King P.O. Box 187 Executive Director Craig, Colorado 81626 Loretta Pineda Director RE: Trapper Mine; C- 1981 -010; SL14 Phase I Bond Release Application Adequacy Review No. 2 Dear Mr. Luke, The Colorado Division of Reclamation, Mining and Safety (Division) has been in the process of finalizing the review of the SL14 bond release application. As you are aware, we have been evaluating the amount of liability that is held in association with the parcels requested for Phase I bond release in the SL14 application. During the site inspection on October 24, 2013 I meet with you, Tim Cummins and Steve Hinkemeyer to discuss the Division's cost estimate for the liability reduction for the SL14 bond release application. During our meeting, the liability associated with the K -Pit was one of the topics discussed. Specifically in regards to the current CIRCES cost estimate that was recently updated with Permit Renewal No. 6, Task 4025. Task 4025 is a Truck and Loader task to haul 5,644,528 cubic yards of spoil to backfill K -Pit. The source of this figure is Table 1.4 -2, of Section 1.4 of Trapper's permit. As I indicated during the meeting, it was unclear to me the actual source of this material and how this volume was calculated. During our meeting, Trapper indicated this volume was derived during the PR6 review and that the Division required Trapper to hold excess bond with this task in association with the mining of K -Pit and the creation of Horse Gulch Fill. After our meeting, I spoke with Dan Hernandez and Jason Musick with the Division who were involved with the PR6 review and the reclamation cost estimate at that time. They directed me to some correspondence to clarify this issue. On December 10, 2008, the Division received a letter from Knight Piesold Consulting responding to the Division's completeness review letter for PR6. One item the letter addressed was a discussion of how boxcut spoil or initial cut spoil was to be returned to K Pit in the event that mining operations proposed for K Pit ceased before the volume of excavated K Pit overburden meets the definition of "excess spoil ". The letter indicates the reclamation liability for the site was re- calculated and an additional reclamation task to haul material from Horse Gulch Fill to backfill the open K -Pit area was added. At that time, K -Pit cross sections were updated for Appendix A and the Determination of Bond section 1.4 of the permit was revised. When PR6 became final these revised section were included in the permit which included the volume in question for Task 425. As a result, the Piesold cost estimate rose to about $28.5 million from $223 million. As indicated above, it appears the volume in question for the truck and loader task was the estimated volume that would have been necessary to backfill the K -Pit open pit area in the event that the mining operations ceased before excess spoil was generated from K -Pit. Upon closer review the Map M6, the Bond Worst Case Year map currently approved in the permit and the K -Pit Cross - Sections 43 and 44 found in Appendix A. It appears material was designated to be trucked back from the Horse Gulch Fill into the K -Pit area. It is unclear to the Division if excess spoil has been and /or is currently being generated from K -Pit and if spoil material currently stored in Horse Gulch Fill is still necessary to backfill the remaining K -Pit open area or other pit excavation at the site, in order for these areas to be reclaimed to the approximate original contour. Parcels K- Office of Office of Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines