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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St, Room 21 S C O L D RA D O <br />Denver, Colorado 80203 D I v 1 5 1 o N O F <br />MIN <br />RA L S <br />Phone: (303) 866-3567 & <br />rax: c3o3) s3z-s1o6 G E O L O G Y <br /> RECLAMATION•NINING <br /> <br />March 16, 2005 SAFETT•SCIENCE <br /> Bill Owens <br />Mr. Forrest Luke Governor <br />Trapper Mining, Inc. Russell George <br />P.O. BOX 187 Executive Director <br />Craig, CO 81626 ow <br />:~o o <br />CxTOrY <br /> l <br />t <br /> Natural Resource Trustee <br />RE: Trapper Mine, C-1981-010, TR-94 Adequacy Concerns <br />Dear Mc Luke: <br />The Division has reviewed Trapper Mining Inc.'s (TMI) application for a technical revision, TR-94, to <br />leave 25 sediment control ponds as permanent impoundments. Please find the Division's following <br />concerns or comments: <br />Please provide the "Extended Qualifier Report" from ACZ labs and /or a description of the codes <br />and meanings of the same for the headings "QUAL" and XQ" for the water sample analysis <br />submitted for the ponds. <br />2. Please provide the rationale for maintaining the Following ponds as permanent related to water <br />level: West Pyeatt #2, Grouse #2, and Deer #1. Other than the notation for West Pyeatt #2 in <br />January of this year, this pond has never held water. Grouse #2 has held water twice in five years <br />and Deer #1 has held water four times in five years. Given the close proximity of the other ponds <br />proposed to be maintained as permanent, maintaining these ponds as permanent would seem to <br />provide little or no benefit (Section 120(2)(h)(IV) of the Act). <br />3. The Division reviewed the currently approved permit application for a description of the water <br />rights held for Trapper Mine. Other than well permits in Appendix Q, no clear description for the <br />surface water rights could be located in the permit. In the well permits application for the open <br />pits (W-1178-77), mention is made to the Synthetic Products Ditch and a conditional water right. <br />Please provide the maximum amount of water that could be held in the permanent pool in the <br />proposed permanent ponds and demonstrate, and identify same, that the mine holds sufficient <br />absolute water rights for this water proposed to be held in permanent pool, considering all other <br />uses and plans for augmentation currently in existence at the mine site (Section 120(2)(h)(VI) of <br />the Act). <br />4. Please provide a plan for distribution of stockpiled topsoil that had been designated for pond <br />reclamation (Section 120(2)(e) and (~ if the Act.). <br />5. Is Trapper Mining proposing a reduction in reclamation cost liability due to a change in the <br />reclamation plan for costs previously associated with reclamation of the ponds proposed to remain <br />Office of Office of Colorado <br />Mined Land Reclamation Active and InaRive Mines Geological Survey <br />