2018-10-25_PERMIT FILE - M2018054 (2)

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Appendix VI Revision to the Application Adequacy Response No.1: October 24, 2018 Colorado Division of Reclamation, Mining and Safety Attn: Ms. Amy Eschberger 1313 Sherman St., Room 215 Denver, CO 80203 RE: Diehl Borrow Pit, File No. M-2018-054 SEMA Construction Inc., Response to the DRMS Adequacy Comments, No. 1 Following are SEMA Construction Inc., (SEMA) responses to the Division of Reclamation, Mining and Safety's (DRMS) Diehl Permit Application, Permit Adequacy Comments, The DRMS comments are in italic font and our responses are in non -italic font. The application replacement pages are included. Most of the revisions are made on the application replacement pages and are shown in italic font. The Adequacy Response is included as a new Appendix VI since not all the responses fit into the application narrative. By making the Adequacy response part of the Application (Amendment VI), all the responses become part of the Application. In terms of the potential plant growth material shortage, if plant growth material is not available, we propose to make up the difference thorough the construction of a suitable plant growth material by the following technique. As you know, the statue and regulations do not require a specific depth of topsoil replacement. In addition, Section 3.1.9 (6) allows the operator to substitute other materials if the amount of topsoil at the site is of poor quality or of insufficient quantity. We therefore propose to modify the sandy material which underlies the proposed material to be mined in the following manner in order to produce up to six inches of suitable plant growth material: • The sandy subsoil will be disked plowed to a depth of at least 12 inches. • We will top -dress the disked subsoil with the available topsoil as evenly as can be done with scrapers. If manure is applied, it will be done at this time. The topsoil and manure will be worked into the disked subsoil to a depth of approximately 6 inches. • We will apply soil amendments per the results of a composite soil sample and analysis. • Phosphorus should be applied during deep disk plowing in order to incorporate the nutrient into the root zone. • If we use organic fertilizer, we will add organic matter in the form of either of the following: Slow release organic fertilizer. These include ✓ Plant -based organic nitrogen sources.