2008-04-11_PERMIT FILE - M2008010

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top soil of any kind be sold during the operation of the pit and that soil stored for future reclamation be fully stabilized to prevent wind and water erosion." Please address these concerns of the Mancos Conservation District. Rule 6.4.5 Exhibit E- Reclamation Plan 5. The submitted reclamation plan and mining plan proposes to use construction debris as backfill. The Reclamation Plan states that the Operator will comply with the regulations regarding use of imported materials for backfill. Please be aware that the proposed use of construction debris will fall under this category and will require the Operator to comply with Rule 3.1:5(9) (Reclamation Measures -Material Handling) of the Construction Materials Rules and Regulations which states that if the operator intends to backfill inert structural fill generated outside of the approved permit area, the operator must notify the office according to guidelines specified in this rule. 6. Rule (2)(f)(ii) of this Exhibit requires the Applicant to specify types, mixtures, quantities, and expected time(s) of seeding and planting for reclamation. The Applicant has stated that revegetation is not part of this reclamation plan. The Applicant states that reclamation in the areas to be reclaimed as cropland will be complete when the first crop is sown in those areas. The Division is agreeable to this criterion. The Applicant further states, however, that seeding of the areas designated as pastureland, will be determined at a later time. The Division requires a proposed seeding plan for areas designated as pastureland, or rangeland, as post-mining land use. Therefore this reclamation plan will require a proposed seed mix, seeding rate, fertilizing, and mulching for those areas designated as pastureland. If the parameters related to reclamation for these areas change, a technical revision will be required when the changed reclamation is incorporated at the site. 7. Rule (2)(f)(v) of this Exhibit requires the Applicant to specify anticipated minimum depth or range of depths of topsoil for those areas where topsoil will be replaced. The Reclamation Plan does not contain this information. Please supply this information related to topsoil replacement depths, and be aware that the Division requires a minimum of 6 inches of replaced topsoil. Rule 6.4.7 Exhibit G- Water Information 8. Section 2 of the submitted Water Information states that reclamation will be important to prevent dissolving salts from the Mancos Shale in exposed areas. Section 6 makes multiple references to the fact that what is currently expressed as surface flow will become subsurface flow following reclamation. Please indicate how reclamation methods used at the site will help prevent dissolving of salts from exposed Mancos Shale. Additionally, please indicate potential impacts of the conversion of surface flow to subsurface flow with regard to the salts contained in these shales. 9. The Mancos Conservation District has submitted similar concerns, with which the Applicant has been supplied, related to the dissolving of salts contained in the Mancos Shale. Please address these concerns. 10. Section 4 of the submitted Water Information states that there will be no significant and permanent changes in watershed boundaries caused by the operations on site. The Mancos Conservation District has submitted a concern, with which the Applicant has been supplied, related to a barrier to surface flow between this proposed operation and an adjacent operation known as the Nolan Pit. The comment states that this barrier will result in ponding that will increase the leaching of salts from the Mancos Shale and the Conservation District recommends removal of this barrier. Please address this concern of the Mancos Conservation District. Rule 6.4.1.9 Exhibit S- Permanent Man-Made Structures 2