2013-01-24_REVISION - C1981010 (2)

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TRAPPER MINEI January 16, 2013 Mr. Jared Ebert Environmental Protection Specialist Colorado Division of Minerals and Geology 1313 Sherman Street, Room 215 Denver, CO 80203 Dear Mr. Ebert: P.O. Box 187 TRAPPER MINING INC. R. Trapper Mining Inc., Permit No. 0414010, Technical Revision TR -110 Water Monitiring.Simpling and Frcgnency Update Craig, Colorado 81626 (970) 824 -4401 RECEIVED JAN 2 4 2013 Division & Please accept this letter as our response to the adequacy review letter of January 7, 2013. In response to Item #1, due to the intermittent nature of discharges through these five outfalls, they rarely record flows. Further information gathered at these outfalls will be sporadic and or non - existent. By placing them into Subpart H of the Western Alkaline Mine Drainage rule, monitoring requirements have been lifted from these watersheds. Under this subpart sediment removal is the primary effluent constituent of concern. With the approval of Phase II bond releases, SL -1, 2, 3, 6, 9, and 12, the lands within these watersheds were demonstrated to meet the sediment removal requirements of the permit. Under Subpart H, areas that do not contain mine runoff and have been re- graded qualify for this classification. Other areas of disturbance that may be included in this designation are grubbing areas, topsoil piles and other reclaimed areas. BMP's for sediment control must be used to attain the effluent limitations of these outfalls. The sediment impoundments will be left in place at these outfalls as the BMP for sediment control. The sediment control plan will be submitted to CDPHE as required per our NPDES permit in order to comply with the effluent requirements of these outfalls. Furthermore, the vast majority of disturbed lands within the respective watersheds have attained Phase III bond release. Specifically, outfall 005 contains 7.1 acres of Phase I lands; the remainder of the water shed is Phase III. Outfall 013 is now entirely Phase III with approximately 25 acres of Phase II reporting to the pond. Outfall 014 is entirely Phase III with 5.2 acres of Phase II reporting to the pond. Outfalls 015 and 016 are entirely Phase III. All of these listed outfalls do contain haul road corridors and active topsoil piles within their respective watersheds. In regard to long term monitoring of these outfalls, there may be very little data gathered due to their intermittent nature. The water quality data gathered to date on these outfalls has not shown any exceedance of the water quality standards in place at the time. It should be feasible to use water quality data from adjoining, similar outfalls to determine any impact to the watershed during final Phase III bond release of these areas. Overall there has not been any issues that may negatively impact the Probable Hydrologic