2013-01-07_REVISION - C1981010 (2)

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STATE OF COLORADO DIVISION OF RECLAMATION, MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 January 7, 2013 John W. Hickenlooper Governor Graham Roberts Mike King Trapper Mining, Inc. Executive Director P.O. Box 187 Loretta Piñeda Craig, Colorado 81626 Director RE: Trapper Mine; C-1981-010; Technical Revision TR110 Water Monitoring Sampling and Frequency Update; Adequacy Review No. 1 Dear Mr. Roberts, The Colorado Division of Reclamation, Mining and Safety (Division) received Technical Revision TR110 on th December 10, 2012. The revision was called complete for review on December 20, 2012. The decision date for the revision is February 18, 2013. There are several items that will need to be addressed prior to the Division’s approval of the revision. These items are discussed below: 1. The revised plan indicates NPDES discharge site 005 (Coyote Gulch), 013 (West Pyeatt Gulch), 014 (Far East Buzzard), 015 (Grouse Gulch), and 016 (Sage Gulch) are no longer required to have effluent limitations or monitoring frequencies. There are still disturbed lands within the watersheds for these discharge points that have not been granted Phase III bond release. During the bond release process, Trapper must be able to demonstrate impacts to the hydrologic balance of the surface water system have been minimized both on and off the mine site to comply with Rule 4.05 and to substantiate Section 4.8.3 the Probable Hydrologic Consequences section of the permit. This analysis is discussed in the “Guidelines Regarding Selected Coal Mine Bond Release Issues”, dated April 18, 1995, under the Phase III bond release guidelines in item number 5. Since effluent limitations and monitoring of these discharge points will no longer occur under the NPDES permit, please explain how that demonstration will be made. 2. The currently approved Operational Surface Water Monitoring Schedule should remain in the permit as a reference for the monitoring conducting during the time period this plan was in effect. There is currently a table on page 4-239a that consists of a historic water monitoring schedule, this table and the currently approved one will need to remain within the permit. The table numbers and titles will need to be updated and appropriately paginated and the table of contents will also need to be revised to reflect the changes. 3. The third paragraph of section 4.8.5.1 Surface Water Monitoring on page 4-239 needs to be updated given the revised monitoring parameters lists and frequency. 4. Please update the third paragraph on page 4-241a to indicate the frequency and parameters for surface water monitoring was updated during this revision (TR110). 5. Monitoring for oil and grease will need to be added for List A-2 parameters on Table 4.8-12. Office of Office of Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines