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INTEROFFICE MEMORANDUM <br />TO, ROB ZUBER <br />FROM: JANET BINNS <br />SUBJECT: TRAPPER MI , 19 1010, S 12 PHASE II BOND RELEASE APPLICATION COMPLETENESS <br />DATE: 10/5/2010 <br />CC: DAN HERNANDEZ <br />As requested I have reviewed Trapper Mining Inc.'s (TMI) application for a Phase II bond release on a <br />portion (173.5 acres) of the reclaimed lands at the Trapper Mine. <br />The operator proposes to request phase II bond release on areas reclaimed in 2005 and 2006 in the <br />Ashmore, Flintlock and East Flintlock (Z) pits. The operator has not stated a monetary amount requested <br />for release. Since this is a requirement of the public notice required by Rule 3.03.2(1)(b) "the portion <br />sought for release" this needs to be stated in the application. If the operator is not seeking monetary <br />release, but only liability release, that should be stated in the application (and in the public notice). <br />• Please have the operator include a statement regarding the amount of bond requested for release, <br />or if liability only is requested, the operator needs to define that request. <br />Vegetation cover reclamation success standards are spelled out on pages 4-101 through 4-103 of the <br />permit. <br />Section 4.4.1.5 of the Trapper Mine permit defines how bond release blocks will be delineated. Bond <br />release application 51.12 varies slightly from the definition in the permit, however, the one parcel in Range <br />Site C, A-C-05, is included in with parcels-that fall within the Range Site A & B designations. Since the <br />success standards for Range Site A & B are more stringent than the success standards for Range Site C, <br />the Division will accept the inclusion of parcel A-C-05 into the SI-12 bond release block. <br />Section 4.4.1.6 of the Trapper Mine permit states that the operator will conduct simple random sampling <br />for bond release vegetation monitoring. However, the operator also reserved the right to use other <br />sampling methodologies as approved by the Division. TMI used a systematic approach to vegetation <br />sampling for the SI-12 application. This approach is acceptable to the Division, and Appendix 2 <br />"Vegetation Transect Summary Table" demonstrated that sample adequacy was achieved. <br />Items 5, 6, 7, 14, 15, and 16 of the Guidelines Regarding Selected Coal Mine Bond Release Issues (April 18, <br />1995), have been found complete for this SI-12 application. I have not reviewed this application for <br />adequacy, only for completeness. Please let me know if you have any questions