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• ~ III IIIIIIIIIIIII III 999 UTAH INTERNATIONAL INC. BOX 187 - CRAIG, COLORADO 81625 303-824-4401 March 27, 1980 i..... I:;,,J Hamlet J. Barry Jr., III ~_;•.~ , ;, ; ;;;Qil Director, Colorado Mined Land Reclamation Division ~ ~,,,i: ,,.•,~,i;_~,; Room 723, Centennial Building ~ '- ~~ 1313 Sherman Street ~ ~~ ~,1". Denver, Colorado 80203 'l~ Dear Mr. Barry: On March 4, 1980, Dennis fJinterringer, OSM inspector, inspected the Trapper Mine for compliance with [he interim performance standards of 30CFR700. As a result of the inspection, Win[erringer cited Trapper Mine for an area of distur- bance a[ [he south end uE our Derringer Pi[ [h a[ he believed lacked sediment control (see enclosed map). Win[erringer is requiring Trapper Mine [o apply for a variance from your office by Ram, April 1, 1980, for the area as allowed for by 30CFR715.17(a). The purpose uE [his correspondence is [o request [he vari- ance per Winterringer's direction. The area in question was noted during one of [he State's inspections last Summer by Roger Funston. Topsoil had been salvaged from the site at the time of the S[a[e inspection but [here were no spoils present. During [he inspection, I pointed out that we intended [o seek a small area exemption for [he site in our permit application pursuant [o the permanent OSM regulations which we plan to file in August, 1980. From [his, we believed further action was unnecessary until [he permit application is filed. The disturbance in question amounts [o a total of 21.54 acres and repre- sents 0.86 Y, of the 2,515.2 acre drainage. Moreover, the disturbance is at the very top of [he drainage and thus dues no[ receive or convey runoff from any area above it. Perhaps even more significantly, a stock dam presently exists about 1,500 feet down drainage from [he disturbance in question. Since design criteria have been suspended for sedimentation dams, [his structure could qualify Lo satisfy 30CFR715.17(a). A field check subsequent [o the March 4th inspection proved [h a[ the structure was no[ Eull and had no[ overflowed in [he recent past. This is particularly meaningful since our precipitation and snowmelt records indicate that we experienced runofF greater than [ha[ expected Erom a 10 year, 24 hour precipitation even[ on February 20th and 29th of [his year. In our opinion, further sediment control for [his area is unnecessary and would be counter productive. It would merely result in additional disturbance without benefits. There is substantial evidence to prove [h a[ runoff from [he site is inconsequential - even from greater Chan a 10 year, 24 our event. We propose the site be granted a small area exemption. 1~ ~~~ ..i,rJ t ~,.