2012-03-27_GENERAL DOCUMENTS - C1981010 ‎(2)‎

• Permit No: C1981010
• IBM Index Class Name: General Documents
• Doc Date: 3/27/2012
• Doc Name: Proposed Decision Findings of Compliance ‎(SL12)‎
• From: DRMS
• To: Trapper Mining Inc
• Permit Index Doc Type: Findings
• Email Name: JLE
• Email Name: SB1
• Media Type: D
• Archive: No

and Regulations. The application also utilized the Division's Guideline Regarding Selected
Coal Mine Bond Release Issues, dated April 18, 1995.
Public Notice
TMI published notice of the bond release application in the Craig Daily Press once weekly
for four consecutive weeks, beginning on September 17, 2010. TMI also notified landowners
within and adjacent to the mine permit area, and other interested parties of the application for
bond release, as required by section 3.03.2(l). The Division received no written comments,
objections, or requests for an informal conference regarding the bond release application.
Bond Release Inspection
The Division scheduled a bond release inspection for October 26, 2010, but inclement
weather prevented the inspection from taking place on that date. Twice more in the fall of
2010, inspection dates were selected (November 9 and November 23), but again bad weather
prevented the inspection from occurring. A wet spring and summer in 2011 further delayed
the inspection, as repairs to the parcels could not be made. The inspection was finally
conducted on August 30, 2011.
The site inspection was conducted in accordance with Section 3.03.2(2). Attendees included:
• Rob Zuber, Colorado Division of Reclamation, Mining, and Safety
• Graham Roberts, Trapper Mining, Inc.
• Elizabeth Shaeffer, Office of Surface Mining (U.S. Department of Interior)
• Jennifer Maiolo, U.S. Bureau of Land Management
• Lane Osborn, the Colorado State Board of Land Commissioners.
For all parcels, the reclamation was found to be generally good, but some issues were
identified as described below.
Summary of Adequacy Review of the Application
On November 28, 2011 the Division sent an adequacy review letter to TMI in regards to the
SL12 Bond Release application. The Division requested parcel A -C -05 be removed from the
bond release application due to inconsistencies regarding the delineation of bond release
blocks and due to the poor vegetative cover established within the parcel. TMI had combined
a range site C parcel with range site A/B blocks which was not approved in the permit. To
resolve the issue of bond release block delineation, TMI submitted a minor revision (MR219)
updating the methodology for block delineation to allow for small range site C parcels to be
included in range site A/B bond release blocks. Also, the Division requested the Operator to
update the Sediment Demonstration to reflect updates to the post- mining herbaceous cover
values in the calculations and to reflect any changes to the revegetation data due to the
removal of parcel A -C -05.
The Division received TMI's response to the adequacy review on February 27, 2012. TMI
Trapper Mine Page 4 March 27, 2012
Phase 11 Bond Release (SL -12)