2011-12-06_REVISION - C1981010

• Permit No: C1981010
• IBM Index Class Name: REVISION
• Doc Date: 12/6/2011
• Doc Name: Adequacy of Bond Release Application Review
• From: DRMS
• To: Trapper Mining, Inc
• Type & Sequence: SL13
• Email Name: RDZ
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
December 1, 2011
To: Rob Zuber
From: Jared Ebert
Re: Trapper Mi e; SL -13 Vegetation Review
CC: Sandy Brown
Block Delineation
Revegetation, Cover and Composition
Cover
Memorandum
STATE OF COLORADO
COLORADO
D I V I S I O N O F
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta E. Pineda
Director
I have conducted a review of Trapper Mining Inc.'s (TMI) application for Phase III bond release on a
portion of the Trapper Mine (C- 1981 -010). TMI is requesting Phase III bond release on the following
parcels; A -B -99, A -B -00, A -B -01, D- AB -99, D -C -99, D- AB -00, F- AB -99, F -AB -00 and F- AB -01.
These parcels were seeded in 1999, 2000, and 2001. Combined, these parcels cover 366.8 acres. The
requested areas were sampled for revegetation success in 2010 and 2011. My review consisted of an
evaluation of TMI's results of their vegetation sampling for plant cover, species diversity, herbaceous
production, woody plant density and shrub survival. For each of these parameters, I conducted an
analysis of the sampling procedures, the statistical analysis for sample adequacy and the Operators
reported success results. These items were compared to the procedures and standards outlined in the
permit and the applicable requirements of Rule 4.15.8 and 4.15.11.
According to TMI's permit section 4.4.1.5, Bond Release Area Delineation, "Bond release blocks for
range site C reclaimed areas will always be comprised solely of range site C reclamation parcels.
Conversely, because of the similarity of their post- mining land uses, parcels from range site A and B
may be lumped together to form an individual bond release block. Moreover, contiguous areas of
range site A and B that were seeded in the same year and receive similar reclamation practices will in
many situations be considered a single reclamation parcel," page 4 -122. For SL13, D -C -99, a range
site C parcel, was included in the bond release block with the other parcels comprised of range site A
and B parcels. Given the language in the permit, parcel D -C -99 should not be included in the current
bond release block. Based on the maps supplied in the SL13 attachments, "Revegetation Monitoring
Report for Reclaimed Areas Samples in (2011 and 2010) on the Trapper Mine," none of the
revegetation monitoring transects were located in this parcel. TMI should remove parcel D -C -99 from
the bond release request. Since none of the sampling transects were located within this parcel and the
small size of this area, removal of the parcel should not impact the revegetation monitoring results for
the rest of the bond release block.
Vegetative cover was sampled in 2010 and 2011 for all the parcels included in the SL13 release
application. For range site A, the required herbaceous cover standard is 33% and 19% litter cover for
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines