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., STATE OF 999 COLORADO DIVISION OF MINERALS AND GEOLOGY DeVanment of Nawral Resources 1313 Sherman SL, Room 215 Denver, Colorado 80203 I ~ Phonc~ U03) 866-7567 ~~~ I FA%: (7031 832-8106 DEPARTMENT OF NATURAL. September 8, 1995 RESOURCES Roy Romer Mr. Forrest Luke cOVefnor Environmental Mana er g lames S Lochhead E..ecuUve Ovecro. Trapper Mi ning Company Michael B. Long n P.O. BDx 107 Division Dueclor Craig, CO 81626 Re: TR-66, Adequacy Review of 1994 Annual Report Trapper Mine, Permit No. C-81-010, Trapper Mining [nc. Deaz Mr. Luke: The Division has finished its review of the 1994 Annual Report for the Trapper Mine. The following are questions and/or comments concerning the report. Section ].0, 1994 Annual Reclamation Report 1. The Division questions why no shrub clumps were established in 1993, and only one in 1994. ,,,~ A2R The standazds of shrub clump spacing delineated in permit page 4-126d describes one 1.6-acre clump spaced not greater than 1400 feet from the neazest clump. This calculates out to an :~ ~~,-,I average of one clump every 63 acres. Table 1.1 in the 1992 Annual Reclamation Report indicates that 36 acres were reclaimed in the Ashmore Pit, and 16.2 acres in the Derrigner Pit, '~ ~~~_ with two mature clumps being constructed at the Derringer area. In 1993, 61.2 acres were reclaimed at the Ashmore Pit, and 41.0 acres at the Derringer Pit, yet no shrub clumps were '~ ~.~a established. According to the 1994 Annual Reclamation Report, there are 146.7 acres at the r,Q....., a. Ashmore Pit, 34.5 acres at the Derringer Pit, and 35.1 acres at the Hawken Pit that have been topsoiled. Only one mature shrub clump was established in 1994 at the Derringer Pit. The Browning and Colt Pits are located primarily in the Range Site C vegetation type and are exempt from a shrub reestablishment standard. Of the acreage reclaimed at the Ashmore Pit, 180.7 acres have been within the A or B Rangesite and are subject to the shrub density standard. According to our estimates from the past three years' reclamation reports, approximately three mature clumps should have been established at the Ashmore Pit. Please clarify why mature shrub transplants have not been constructed in the Ashmore Pit area. Creation of three mature shrub transplant areas over the last three years in the Derringer Pit appeazs to be keeping up with the spacing commitment stated in the permit.