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<br /> <br />including specific mitigation measures and timeframes that will be implemented to ensure <br />compliance with these rules. <br />14.If it cannot be demonstrated that the plumes of hazardous materials, including the RCRA <br />metals, will not be affected by the mining operation, and that the water contained or <br />exposed in the pit at any time during the life of mine meets or exceeds the NPDES discharge <br />criteria, please commit to installation of a berm on the west end of the pit, prior to <br />excavation of Phase 5, that will be adequate to prevent the 10D year flood from entering <br />the excavation area. Approval from the Army Corps of Engineers may be required for <br />installation of this berm. <br />15.Equipment used in gravel mining operations almost invariably leak oils and grease onto the <br />pit floor. These products often cause a sheen on water within the pit, potentiaNy leading to <br />numerous false reports of Fruita Refinery related contamination within the pit. Please <br />address this potential problem. <br />16. Please submit all updated pages for the Waste Management Contingency Plan. Specifically, <br />Table 2 and the Appendix B Site Inspection Form that include well MW-5. <br />Exhibit E -Reclamation Plan <br />17.With a post mining land use specified for wildlife habitat, and ample excess overburden to <br />work with, the reclamation plan should be revised to include undulating pit slopes with <br />grades varying from 3H:1 V to 8H:1 V. <br />18.To improve the diversity of the seed mix proposed for the staging area it is recommended <br />that FulYs alkali grass and Indian rice grass be added. The Indian rice grass may require a <br />Separate seeding because of the increased depth at which the seed must be planted <br />compared to other grass species. <br />19.The permit application indicates the majority of the proposed permit area and surrounding <br />area is stripped of vegetation, except for some sparse weedy species, due to past non- <br />mining related operations. Therefore, success of vegetation establishment for reclamation <br />of the site will be based on the effectiveness of the re-established vegetative cover to <br />stabilize the affected area surfaces. As specified by Rule 3.1.10(11, the vegetative cover <br />must be diverse, effective, long-lasting and capable of self-regeneration without irrigation, <br />fertilizer or amendments. The proposed standard of 10 percent live perennial cover is most <br />likely not adequate to stabilize the upland portions of the site. Please contact the Natural <br />Resource Conservation Service (NRCS) for general guidelines on establishing success criteria <br />for the upland and wetland areas. <br />20. Please commit to obtaining representative soil samples from the areas that are topsoiled and <br />the areas to be revegetated that do not receive topsoil and have the samples analyzed. <br />Please commit to apply the fertilizer or soil amendments as recommended in the soil <br />analysis results. <br />21.Please commit to ripping, discing or chisel plowing of areas to be topsoiled immediately <br />prior to topsoil replacement, <br />