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Submittal of Bond Release Application and Completeness Determination by the Division <br />The Division received Trapper Mine's bond release application SL -14 on May 13, 2013. The <br />application was found complete on July 18, 2013, after the Division received proof of publication of <br />the applicant's public notice. The completeness determination was made in accordance with Section <br />3.03.2(1)(d). <br />Trapper Mine submitted the bond release application following the procedures described in the Act <br />and Regulations. Furthermore, the application is in agreement with the Division's Guideline <br />Re a�g Selected Coal Mine Bond Release Issues, dated April 18, 1995. <br />Public Notice <br />Trapper Mine published notice of the bond release application in the Craig Daily Press once weekly <br />for four consecutive weeks, beginning on May 24, 2013. Trapper Mine also notified landowners <br />within and adjacent to the mine permit area, and other interested parties of the application for bond <br />release, as required by section 3.012(1). The Division received no written comments, objections, or <br />requests for an informal conference regarding the bond release application. <br />Bond Release Inspection <br />The Division scheduled and conducted a bond release inspection on August 15, 2013. Notification of <br />the inspection was sent to the operator, surface owners and the Office of Surface Mining (OSM). The <br />site inspection was conducted in accordance with Section 3.03.2(2). Jared Ebert represented the <br />Colorado Division of Reclamation, Mining, and Safety (Division). The operator was represented by <br />Graham Roberts of Trapper Mining, Inc. Also at the inspection was Dan Mackinnon of the Office of <br />Surface Mining. It was determined during this inspection that some channel erosion and drainage <br />maintenance was needed in the reconstructed Middle Pyeatt drainage within bond release parcel A-13- <br />10 and the Oak Gulch drainage within Parcel A -13-09. Also, a portion of the Each Pyeatt drainage <br />within parcels F -A -12 and Z -A -12 is in the process of being constructed. The Division and TMI are <br />currently evaluating the drainage reconstruction and stabilization plan approved in the permit as part of <br />Permit Revision No. 7. Given the channel erosion observed during the inspection of the Middle Pyeatt <br />and Oak Gulch reconstructed channels and the future stabilization of the portion of the East Pyeatt <br />channel, these portions of the drainages were not eligible for bond release. <br />Adequacv Review of SL -14 Application <br />The Division sent an adequacy review letter to TMI on September 6, 2013. The letter cited two items <br />in regards to the drainage reconstruction issues noted during the bond release inspection. The Division <br />requested that Trapper delineate a corridor around each of these channels for future maintenance and <br />construction efforts. This corridor area would then be excluded from Phase I bond release. <br />Trapper responded to the Division's adequacy review on September 30, 2013. Trapper delineated the <br />corridors around the drainages in question and removed those areas from the Phase I bond release <br />request. Trapper's original Phase I bond release request was for 424.2 acres of land. The drainage <br />corridors in question encompassed 6.4 acres, thus reducing the bond release area to 417.8 acres. <br />After further review of the reclamation liability cost estimate for the Trapper Mine, a question arose in <br />regards to the liability associated with parcels K -A -10 and K -A -11. These parcels encompass a portion <br />Trapper Mine Page 5 December 2013 <br />SL -14 Phase I Bond Release <br />