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October 14, 2005 Trapper Mining, Inc. (TMI) PO Box Craig, CO Trapper Mine Special focus evaluation October 11 & 12, 2005 Participants: Janet Binns, Colorado Division of Minerals and Geology (DMG) Forrest Luke, TMI Henry Austin, Office of Surface Mining (OSM) I participated in a special focus evaluation of topsoil removal and replacement practices at the Trapper Mine. This special focus topic was selected by the DMG/OSM Oversight Team for evaluation during evaluation year 2006. The topic included evaluation of approved annual time frames, schedules, approved locations, and annual acreage commitments for completing topsoil replacement found in the current DMG mining permit; and field evaluation to confirm replacement of approved topsoil depths. Topsoil replacement requirements are 12 inches plus or minus 2 inches for rangeland, and 18 inches plus or minus 2 inches for cropland. We began the evaluation by reviewing applicable portions of the approved mining and reclamation plan (MRP) in the TMI offices. Specifically we reviewed, Map M lOB, approved 070505, Topsoil stripping & Reclaim (from MR 201-showing years 2003 thru 2007 ); Table 1.1 Reclamation Summazy for Trapper Mine (2004) from the 2004 Annual Reclamation Report (ARR); and pages 4-260 thru 4-263 from the approved MRP (These pages describe topsoil removal and replacement procedures including Table 4.9-3 (MRP page 4-261) Bank Cubic Yazds (BCY) of topsoil to be salvaged and replaced by pit from 2003-2007 and the resultant drawdown or increase of stockpile inventory. Inspection participants discussed that this table's title could change to Projected Bank Cubic Yards (PBCY), to more accurately title this work projection table, and Table 4.9-4 (MRP page 4-262) Projected topsoil inventory, and the TR 95-2004 Annual Reclamation Report Map. We also discussed how TR-96, which is currently under review and other approved MRP changes, will affect the maps we are reviewing for this evaluation, and other related maps as well. We compared the information on the maps, MRP pages, and the 2004 ARR above, to actual completed and projected topsoil stripping and topsoil replacement areas by discussion among participants about what has been completed and planned for CY 2005. We also compared the above maps with one another. There are slight differences in these maps and topsoil information resources that can be expected every year of course, depending on operational, weather, and other factors that affect topsoil removal and replacement. Inspection participants discussed narrating these differences in the ARR, to the extent possible, to describe how the above operational factors have or will affect topsoil removal and replacement during any given year, and thus what to approximate annually for differences between approved maps and MRP language, and what is actually being accomplished in the field. This narration in the ARR may be a recommendation of this evaluation.