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~. - - <br />~II ~II~I~~III~~~~I~ <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparlmem ui Nalu rat Rewurces <br />131 3 Sherman 51., Room 215 <br />Denver, Culurado 80'03 <br />Phone: 1 1031 866-3567 <br />FAX: 13031 83?-8106 <br />DATE: DECEMBER 5, 1995 <br />STATE OF COLORADO <br />~~~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Romer <br />Governor <br />TO: JANET BINNS TONY WALDRON Tames S. Lochhead <br />/ Eeecvhve Dvecmr <br />Mn hael B. Lonp <br />FROM: JOE DUDASH ~ ~ ~ Division Director <br />Re: DRAFT QUESTION ON TOPSOIL <br />Technical Revision No. 66, 1994 Annual Report, Trapper Mine, <br />Permit No. C-81-010, Trapper Mining, Inc. <br />The following is a proposed reply to Trapper's response of our <br />adequacy question concerning surplus topsoil. The original question <br />was formulated by Janet. This reply was compiled from discussions <br />that I have had with Dave B., Tony W. and Janet B. If you have any <br />questions, please let me know. Thanks! <br />Section 1.0. 1994 Annual Reclamation Report <br />The operator has requested that the surplus topsoil plan be <br />deferred until the next permit term. However, the Division is <br />very concerned about both the magnitude of the surplus topsoil <br />and also the lack of a specific plan to deal with this excess. <br />Because of these concerns, the Division believes that it and <br />Trapper must come to some resolution in regard to the surplus <br />topsoil. The Division wishes to make several points. <br />First, the Division believes that the regulations require that <br />all topsoil must be used for reclamation. Rule 2.04.9 requires <br />that the operator submit a baseline soils resource study. From <br />this study, it is determined how much topsoil is salvageable, <br />as required by Rules 2.05.3(5) and 4.06.2(2)(b). Under Rule <br />4.06.1(2), topsoil is required to be immediately redistributed <br />or to be stockpiled according to Rule 4.06.3. Rule 4.06.3(1) <br />states that the redistribution is to be on regraded areas. In <br />other words, all of the topsoil is to be salvaged, and all of <br />the topsoil is to be used for reclamation. <br />The Division recognizes that, in the real world, it is not <br />possible to be exact with topsoil removal and replacement <br />depth estimates. After reclamation at any mine, there will be <br />either some topsoil left over or some topsoil that will need <br />