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,. ~~I I~~II~II~~~~~ II~ TRAPPER ~ININC I1~C. April 9, 1998 Mr. Kent Gorham RECEIVED Environmental Protection Specialist APR 13 Colorado Division of Minerals & Geology 1998 1313 Shcnnan Street, Room 215 Denver. CO 80203 Division of Mine2ls 8 GeObgy Re: Trapper Mining Inc., Permit No. C-81-010 Discussion of N.O.V. No. CV-98-003 Deaz Mr. Gorham: This letter outlines Trapper's discussion concerning the conditions surrounding the above- captioned violation that was issued to us on March 26, 1998. The flood conditions encountered on that day were the result of a veq~ unusual set of conditions that were beyond Trapper's ability to control. We would ask the Division to consider the following facts when considering whether a violation actually occurred and whether any civil penalty should be assessed: • On the same day that flooding was occurring at Trapper Mine, extensive flooding was occurring just a few miles away in and around the city of Craig. Flooding in Craig included Fortification Creek--which runs through the middle oftown--running out of its banks into the 500-year floodplain and causing the evacuation of numerous homes; storm sewers near the Moffat County wurthouse exceeded their drainage capacity and flooded the surrounding area; and several county roads around Craig were washed out and closed because of flood waters. The flooding azound Craig was the lead story on the major Denver television stations March 25 and 26. The Denver press went to great pains during their broadcasts to emphasize that this flooding was the result of an unusual set of circumstances unique to the Craig area and did not constitute an overall flooding threat to the state as a whole. The Craig area flooding is documented in the enclosed articles from the Craig Daily Press. • Temperatures in the mid-60's that occured on March 25 and 26 caused an incredibly rapid snowmelt throughout the Craig area. This rapid snowmelt was exacerbated by saturated soil conditions stemming from the earlier initiation of the snowmelt season while soils were still likely frozen at depth. In addition, it is probable that soils saturated from the 100-year flood event of last fall had been unable to dry out and recover to typical seasonal moisture levels over the winter. • Another contributing factor to the flooding was a wet snowstorm that occurred the previous week (March 17-18) that totaled 0.78 inch of precipitation. The precipitation from this event ran off along with existing snow pack in one large surge with the rapid temperature rise that we experienced on March 25 and 26. P.O. Box 187 Craig, Colorado 81626 (303) 824-4401