2008-04-25_PERMIT FILE - M2008010

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Letter: Response to adequacy review, Permit Application M-2008-010 4/25/2008 page 7 Recommendations from NRCS and Southwest Seeds (which headquarters are located about 15 miles from this site) are that fertilizer rates should be determined at the time of planting, since soil conditions are likely to be quite variable, that mulch is not needed except on slopes greater than 4H:1 V, where aspen excelsior (manufactured in Mancos, approximately 2 miles away) can be applied to cover the seeded area, and used as a mulch superior to straw mulch and less likely to have weed seeds. Otherwise, straw mulch would be applied at a rate of 2 tons per acre and crimped in to a depth of 3 inches or less. Tackifier is not recommended. 7. Topsoil depth for reclamation: The reference to "Rule (2)(f)(v) of this Exhibit" is confusing; please explain. However, the depth of topsoil to be placed on areas to be reclaimed to cropland or pasture land is stated in Exhibit I -Soils Information (paragraph 6, third bullet) as twelve inches, which exceeds the Mineral Rules and Regulations requirement. We apologize for the error in the reference to this information on page 22 ("Topsoil" paragraph) and page 23 (Section E-4), where Exhibit I is mistakenly identified as B and Exhibit D is mistakenly identified as C. (These items are shown in the errata sheet.) There is also a reference to other exhibits provided at the bottom of page 23. 5 8. ; ,Impact of reclamation and Mancos shale on water salinity: Reclamation will cover Mancos shale exposed during mining. Since backfilled material and topsoil will be placed on top of the shale (as on a'll portions of the floor of the pit), the Mancos shale will not remain exposed and surface runoff will not come in direct contact with the shale, nor erode it away and thus dissolve salts out of the shale. Without surface discharge, storm water which falls on Mancos shale exposed on the floor of the pit during mining and before reclamation will flow along the upper surface and either evaporate (thus leaving the salts in place) or will flow through the remaining alluvium, just as if it fell directly on the alluvium. Fines transported on the surface will be deposited on the surface of the remaining alluvium and on the top of the shale. Although the benefit of the filtration through these materials will be limited for dissolved materials in the water, it will still provide for a; purification process similar to the previous situation in which much of the water soaked into the soil. Since Mancos shale is generally s "Items specified for the Reclamation Plan in Rule 6 have been included in other items in this Exhibit or have been included in other Exhibits referenced above, and therefore are not separately listed in this exhibit."