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Bond Reicase Inspection <br />The Division conducted a bond release inspection on November 4, ~, and 6, 1996. The site <br />inspection was conducted in accordance with Section 3.03?(2j. Forrest Luke represented Trapper. <br />as their environmental manager. The Division was represented by Joe Dudash, David Berrv, and <br />Bill Carter. The Office of Surface Mining was represented by 4litch Rollins. Janet Hook <br />represented the Bureau of Land Iv(anagement. The only two landowners who were involved in this <br />bond release request are Trapper N(ining Inc. and the State of Colorado. <br />Technical Review <br />The Division reviewed technical aspects of Trapper's bond release submittal in order to determine <br />if Phase II bond release is warranted. The review evaluated the methods that Trapper used in <br />gathering and processing the data in the bond release submittal. The review considered the technical <br />validity of conclusions presented in the submittal. Those conclusions were then compared to the <br />requirements of Trapper's approved reclamation plan and to the regulatory requirements for Phase <br />II bond release. <br />Adeauacv Questions and Responses <br />The Division identified three adequacy issues during the review of Trapper's bond release submittal. <br />One issue involved the inclusion of pazcel D-A-84 in the Phase II bond release request. The parcel <br />had been seeded in 1983 and 1984. The parcel was sampled for vegetative cover and diversity in <br />199. However, a portion of the pazcel was redisturbed, regraded and reseeded in late summer of <br />1996 when the operator removed topsoil stockpile D77-1. Therefore, this portion of the pazcel would <br />not qualify for Phase II bond release because the vegetation data in the submittal no longer applies. <br />The Division informed the operator of this issue and gave the operator the choice of either having <br />the Division reject that pazcel from consideration, or having the operator revise the Phase II <br />submittal by removing that portion of the parcel D-A-84 from consideration. The operator chose to <br />revise the submittal. In a submittal received at the Division on September 22, 1997, the operator <br />divided pazcel D-A-84 into two pazcels, D-A-84 and D-A-84a, the latter of which was excluded from <br />Phase II consideration. <br />The second adequacy issue was resolved by Trapper submitting an explanation of its basis for <br />considering reclaimed parcels as "contoured" in selecting a CP factor for the runoff curve number. <br />The third issue was resolved by Trapper submitting data from pond sediment surveys for the <br />Division's calculation of sediment yield in Coyote drainage. <br />Comments and Objections <br />The Division received no comments, written objections, or requests fur an informal conference <br />regarding the bond release application. <br />Trapper Mine Page 3 }2114198 <br />Phase II Bond Release <br />