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Rule 6.4.5 Exhibit E -Reclamation Plan <br />1. Rule 6.4.5 (1)(a) requires a discussion of why the proposed type(s) of reclamation <br />was chosen. Please provide a brief discussion describing the reasoning behind the <br />proposed method(s) of reclamation. <br />2. Rule 6.4.5 (1)(c) requires a description of how the Reclamation Plan will be <br />implemented to meet each applicable requirement of Rule 3.1. In this regard, the <br />division has the following questions/concerns: <br />A. Lafazge states that the site will be reclaimed to rangeland and developed water. <br />As the current land use is primarily irrigated agricultural, we aze somewhat <br />confused as to why the proposed post-mining land use is designated as rangeland. <br />Please provide the rationale for such a designation. <br />B. Please provide a statement to the effect that each phase of reclamation shall be <br />completed within five (5) yeazs from the date the Operator informs the Boazd or <br />Office that such phase has commenced, unless extended by the Boazd or Office. <br />C. Please state whether backfilled material will be compacted. <br />D. Please confirm whether or not there will be any drill or auger holes that aze <br />part of the mining operation, and if so, assurance that they will be plugged with <br />non-combustible material, which shall prevent harmful or polluting drainage. <br />E. A statement that mined material to be disposed of within the affected area <br />will be handled in such a manner so as to prevent any unauthorized release of <br />pollutants to the surface drainage system. <br />F. A statement that no unauthorized release of pollutants to groundwater shall <br />occur from any materials mined, handled or disposed of within the permit azea. <br />3. Rule 6.4.5(2) (d) & (f)(v) requires a plan for topsoil segregation, preservation, and <br />replacement depths. Under Exhibit D (Mining Plan) you discuss various aspects <br />of topsoil removal and handling but specifically fail to mention how much topsoil <br />will be removed and reserved for later use in reclamation. Soil surveys often <br />describe "surface layers" which tends to be interpreted as topsoil; however, the <br />effective rooting depths are also a very strong indicator of the soil profile, <br />especially when dealing with entisols or recently developed soils such as those <br />often found in alluvial situations. In most of the soils present on this site the <br />effective rooting depth is 60 inches or more, indicating that subsoil plays an <br />important role in support of the vegetative community. <br />Under the reclamation plan you do mention that "at least 6 inches" of topsoil will <br />be re-spread over disturbed areas to provide a suitable medium for revegetation. <br />