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• • iii iiiiiiiiiiiu iii 999 DEPARTMENT OF NATURAL RESOURCES David H. Gelches, Executive Director MINED LAND RECLAMATION DIVISION DAVID C. SHELTON, Director Richartl D. Lamm Governor DATE: June 27, 1984 T0: .Susan Mowry and Brian Munson FROM: Michael S. Savage rsnvak~ RE: Trapper Mining (C-010-81) Correspondence Proposing Reclamation Standards for Older Areas at the Trapper Mine Susan, I have reviewed the correspondence fran Trapper Mining dated January 26, 1984 which proposes reclamation standards for areas disturbed prior to 1978, and the Empire Energy disturbance. I have several concerns regarding their proposal and have enumerated them below. In short, Trapper Mining has proposed to set a vegetative cover success standard for all areas which were disturbed prior to May 3, 1978. Additionally, they have proposed a vegetative cover success standard for the Empire Energy pit which they have committed to reclaim but was disturbed prior to Trapper Minings entering the area. In reviewing the maps Trapper has submitted it became very evident that areas they considered disturbed prior to May 3, 1978 included many of the extant haul roads, facilities areas, and accessways. It has been the policy of the Division that areas which were disturbed prior to a company entering and not reclaimed in accordance with the permanent regulations would not be subject to the same revegetation success criteria as those areas which were disturbed by the mining company under the permitted program. In my opinion, Trapper has tried to circumvent this requirement by stating that a number of their areas were disturbed prior to a "magical" date of May 3, 1978. In conversations with Sandy Emrich, who has dealt with a similar situation with the Eckman Park Mine and Getty Corporation, it was determined that areas which are currently extant or in use have always been considered to be under the permanent program. It is therefore my recommendation that Trapper be required to reclaim all areas which were in use at the time of the state permanent program approval (December 15, 1980) to the revegetation success standards approved in their permanent program permit. Any areas which were reclaimed (graded, topsoiled, and seeded) prior to the December 15, 1980 state program approval, I would recommend being evaluated under the interim program revegetation success criteria. With regard to the Empire Energy pit, Trapper states that the area will not be topsoiled, therefore, normal rangeland seed mixes are not appropriate. Trapper has also set a revegetation cover standard of 30% vegetative cover. I feel the Division can accept the revegetation success criteria of 30%, as this is consistent with Rule 4.15.10 for previously mined lands. I do question the species proposed for the mix in this area as there are several introduced species. 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (303) 866-3567