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DATE: December 12. 1997 TO: Lloyd V. "Buck" Barnhart ~1~~ FROM: Larry D. Oehler, Environmental Protection Specialist RE: File No. M-97-087, JBCO, Hartman Pit, Adequacy Items The following items must be addressed by the applicant in order to satisfy the applicable requirements of C.R.S. 34-32.5-101 et sec .. and the Construction Materials Rules and Regulations of the Mined Land Reclamation Boazd: Exhibit D -Mining Plan 1. The Division is concerned that if the top 4" - 8" of topsoil is to be salvaged and used as topsoil in reclamation and this fraction of the soil profile is 60% cobbles that upon replacement the cobbles will remain on the surface and the organic soil will essentially be buried. The Division recommends that the topsoil be screened of rock lazger than 2 inches, sepazately from other screening operations. The remaining topsoil and small rock should then be mixed with an equal amount of fines before being spread as topsoil. This soil material should then be further amended with 20 tons/acre of manure. If the cobbles were to remain in the topsoil, it would probably not be possible to drill seed the reclamation mix and the mix would have to be doubled to broadcast seed it. Either commit to this change of the reclamation plan (no Technical Revision) or provide your own plan to solve the above problems. 2. Incorporate into the Mining Plan and on the Mining Plan Map the requirements of the CIG agreement such as remaining 50 feet away from either side of the pipeline and establishing 4: I slopes from that point to the pit floor. Exhibit E -Reclamation Plan The Division recommends that the berm around the edge of the reclaimed azea be taken out of the plan. Such a berm would not be constructed on the level (contour) and would act as a diversion overland flow. The diverted water would no doubt break the berm in low areas concentrating flows and causing erosion of the hill slopes below the pit and in some instances possible off site damage. Such berms unless build on the contour or to a grade not exceeding 2 or 3%a and spilling to a constructed catchment basin or protected waterway could do more harm than good. Establishment of a good vegetative cover would be a better erosion control method. You stated that if topsoil or growth media is to remain in stockpiles for more than one growing season an SCS (NRCS) recommended vegetative cover shall be employed... Only a Final revegetation seed mix was found in your plan, this mix is not very suitable for establishing a quick vegetative cover. These grasses take too long to establish. The Division recommends that you commit to using the following mix or a similar mix. These are large seeded cool season grasses that establish more readily when moisture is more likely to be available in the area.