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The phase 1 processing area will remain and serve as processing area for phase 2. <br /> 20. On page D-5, the application states that segregated plant debris (compacted mixed <br /> trees and sandy loam/forest litter) will be stockpiled along the northeastern edge of the <br /> proposed processing area, and this berm will be compacted, topped with at least 6 <br /> inches of topsoil, and seeded to protect the berm from erosion and create a more <br /> aesthetically pleasing screening berm. Please clarify if this material is expected to be <br /> used as a growth medium for reclamation. Is the applicant proposing to combine any <br /> salvaged topsoil with woody vegetation in these berms, or will topsoil be stored <br /> separately?Per Rule 3.1.9(2), an operator should make a reasonable effort to ensure <br /> that existing vegetation is put to a beneficial use such as firewood, mulching, lumber, <br /> etc. Has the applicant considered using the woody vegetation in this manner rather than <br /> storing it in the proposed berms? Given the limited amount of topsoil available on site, <br /> any topsoil salvaged during operations should be protected for use in reclamation. The <br /> Division does not recommend the applicant use the limited topsoil available to "top" <br /> vegetative piles. Please modify this exhibit accordingly. Also, please be sure any <br /> proposed growth medium stockpiles are shown on the applicable mining plan maps in <br /> Exhibit C. <br /> Please see the revisions in Exhibit D of the permit narrative where reference to a screening <br /> berm has been removed. Reclamation materials will be stockpiled in the phase 1 processing <br /> area, only as needed. The site will mine and reclaim concurrently such that long term stockpiling <br /> of reclamation materials is not necessary. Refer to the Applicant's response to question #15 for <br /> additional information regarding stockpiled materials. <br /> Partially decomposed plant material, sandy loam, and site derived tree mulch paired with <br /> crusher fines, as needed, will be used a growth medium. This method of creating substitute <br /> topsoil will reuse site derived nutrients and will serve as adequate topsoil in lieu of otherwise <br /> absent true topsoil stripped from pre-mined areas. Coarse blasted rock will serve as `rock <br /> mulch' by reducing soil erosion and providing `micro-climates' for seed germination by <br /> increasing shade, moisture retention, and protection from drying winds. No true topsoil is found <br /> at the site; however, site derived materials will be adequate to provide growth medium to native <br /> species used in reclamation (similar to what has been observed on the fill sections of the CCP <br /> construction). <br /> Whole trees stripped prior to mining will be used to provide mulchy growth medium on reclaimed <br /> slopes within the mine and on the WRL. These organic site derived mulches will be combined <br /> with processing fines to create substitute topsoil to be used in reclamation. This method of <br /> creating substitute topsoil will reuse site derived nutrients and will serve as adequate topsoil in <br /> lieu of otherwise absent true topsoil stripped from pre-mined areas. When available, large trees <br /> will be used as mulch which will also be stored as a Reclamation material in the phase 1 <br /> processing area. <br /> 21. Please provide the seed mixture that will be used to stabilize any temporary growth <br /> medium stockpiles. <br /> All stockpiles throughout the site, when in place beyond 180 days, will be seeded with dry <br /> rangeland grass mix as detailed in Table 5 in Exhibit E. <br /> December 2021 7 Lcwicki 91 Associates <br />