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<br />Edward Settle 2 August 14, 1997 <br />Clifton Water Gravel Pit M-97-053 <br />in compliance with CDPHE Colorado Discharge Permit System (CDPS). Please <br />demonstrate compliance with applicable federal and Colorado water quality laws, <br />required by Rule 3.1.6(1)(b-, by submitting copy of approval document from <br />CDPHE for the CDPS application. <br />Topsoil Stockpile -Mining Plan states that the top 0.5' layer of overburden will be <br />salvaged as topsoil. Topsoil will be stockpiled within the 30' and 100' buffer <br />zones surrounding the pit area and replaced over pond inslopes during reclamation. <br />Please note that Rule 3.1.9 requires that topsoil be stockpiled in a stable <br />configuration and protected from deterioration. Generally, topsoil stockpiles are <br />stabilized by maintaining 3H:1 V side slopes and protective vegetative cover. <br />Operator is required to establish protective vegetative cover for all topsoil <br />stockpiles to remain in place for periods exceeding 1 year. <br />Reclamation Seed Mix -Rule 3.1.1011) requires that the operator establish a diverse <br />vegetative cover, at least equal in extent of cover to the natural vegetation of the <br />surrounding area. Original seed mix proposed in the application is limited to three <br />cool season grasses: Indian ricegrass; Crested wheatgrass; and Thickspike <br />wheatgrass. Diversity in the final vegetative cover will be difficult to achieve with <br />the submitted seed mix. Please augment the reclamation seed mix by including <br />additional species. Suggestions are provided in the enclosed DMG 12/7/83 letter <br />to Elam Construction, and in the two page list of saline or alkaline tolerant grasses. <br />In addition to including a greater variety of grasses, please also include a nitrogen <br />fixing legume, as required by Rule 3.1.10(4). DMG recommendations include <br />Sainfoin, Red clover, or Birdsfoot trefoil. <br />Reclamation Plan does not indicate that revegetation efforts will include fertilizer <br />and mulch treatments. DMG experience with revegetation efforts in Mesa County <br />indicate a 50% failure rate. DMG will calculate reclamation cost to include <br />revegetation failure rate in excess of 50%, unless fertilizer and mulch is included in <br />revegetation efforts. <br />Please contact me at the DMG Durango office, 484 Turner Drive, Building F, Suite 101, <br />Durango, CO 81301, phone (970) 247-5193, if you have any questions. <br />Since/r/e7ly,~ / <br />~~d~~11~11 ~~ <br />Wallace H. Erickson <br />Environmental Protection Plan <br />Enclosure(s) <br />