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<br /> <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br />John W. Hickenlooper, Governor | Mike King, Executive Director | Virginia Brannon, Director <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br /> <br />Memorandum <br /> <br />Date: June 17, 2016 <br /> <br />TO: Tabetha Lynch, DRMS <br /> <br />From: Jared Ebert, DRMS <br /> <br />RE: Trapper Mine; C-1981-010, Technical Revision 115 (TR115), Cost Estimate <br /> <br />On June 13, 2016, Trapper Mining, Inc. (Trapper or TMI) responded to each of the adequacy <br />review comments that I had originally sent you with my initial memo that you incorporated into <br />your adequacy review letter. I have reviewed their response to my initial adequacy questions. I <br />have bulleted each of my initial adequacy comments followed by a summary of Trapper’s <br />response and provided my response. Additional adequacy items are bulleted. <br /> <br />49.7 Acres of New Topsoil Stripping Area <br /> <br /> The topsoil stripping and replacement plan shown on the TR115, M10B Sheet 3 map <br />does not appear to be consistent with the topsoil replacement that has occurred for 2014 <br />and 2015, nor what is projected to be replaced in 2016. Also the 2015 Annual <br />Reclamation Report Map depicts a proposed topsoil stripping parcel for 2016 that is <br />within portions of the 2016 parcel and portions of the proposed 2017 topsoil stripping <br />parcel depicted on Map M10B. Please review the topsoil stripping plan and replacement <br />plan depicted on the proposed M10B map and reconcile it with what has occurred to date <br />and what Trapper plans in 2016 and 2017. <br />o Trapper’s Response: They declined to update these maps for the reasons <br />outlined in their response to the 2nd item of the Division’s adequacy letter. <br />o Division’s Response: Historically, the Division has given Trapper flexibility in <br />operations within the area approved for disturbance within a permit term. <br />However, the Division must be cautious that Trapper is adequately bonded and <br />this is done by evaluating that the worst case disturbance bonded for has not been <br />exceeded. The M4, M4a, M6 and M10 series maps and the tables and narrative <br />in section 1.4, 3.0 and Appendix A of the permit as well as the annual reports <br />allow us to make this evaluation to some degree. As you know, we discussed <br />this with TMI during our phone conversation with Graham Roberts on June 16, <br />2016. I believe we agree that TMI should update the M10B series maps to depict <br />the actual topsoil removal and replacement plan. <br /> Based on the item above, please review Table 3.1-3 on proposed revised page 3-13 and <br />make any necessary updates to the topsoil replacement balance for the permit term.