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.1A~~ `~. .~ • • III IIIIIIIIIIIII III ~~~°~9~Q STATE OF COLOR~L~v Roy Romer, Govei DEPARTMENT OF NATURAL RESOURCES MINED LAND RECLAMATION DIVISION DAVID C. SHELTON, Dlroctor DATE: March 25, 1987 T0: Gregg Squire FROM: Jeff Deckler '~ RE: TRAPPER PERMIT REVISION N0. O1, ADEQUACY COMMENTS ON 1987 OPERATIONS, FILE N0. C-81-010 I have reviewed the above referenced PR with respect to Topsoil and Bonding issues. In addition, I have a philosophical comment. I. Philosophy This proposed revision presents a part of the total mine plan for the Colt and Browning pits. As such I believe this revision should be incorporated into PR2, and the complete mine plan reviewed at one time. Our job is to permit coal mines, not topsoiling operations, and on the slim chance that the pit wasn't approved, I would hate to think that they ripped up 96 acres for nothing. In addition, many issues overlap in the two PR's, creating a piece meal approach and duplication of effort. II. Topsoil The revision does not present any specific information with respect to soils in the new pit areas. The operator's basic statement is that everything is the same as in the original permit. This is not adequate. The operator must provide information on stripping depths for each soil unit, total volume stripped, and volumes placed in each proposed stockpile. These quantities are necessary fora complete review of the plan, and for bonding calculations. In addition, based on the current topsoil salvage problems, the operator must verify the estimated stripping depths. As discussed more fully in my PR 02 review, topsoil salvage depths at Trapper have been significantly different than those estimated by the baseline soils inventory. Therefore, Trapper must submit a material balance which shows that sufficient topsoil can be salvaged to implement the reclamation plan. In addition, the Division reserves the right to require Trapper to resample in order to verify the estimated stripping depths for the new area. Additional information will also be required for PR 02, including an explanation for this discrepancy. Lastly, in overlaying the topsoil stripping and blasting maps, I noted that some areas to be blasted will not have topsoil stripped. It is possible that these areas are part of the existing pit and are therefore already disturbed. Trapper should explain this apparent anomaly. 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. (303) 866-3567