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it <br />these materials might be used to~improve the soil, if analysis indicates the structure and/or fertility will be <br />improved by the addition of some certain amount of those materials. <br />Please commit to the types of topsoil that will be reserved at the site. Please commit to the depth of topsoil <br />replacement in the irrigated pasture areas at the site. Please indicate how and when it will be determined as to <br />the adequate amount of topsoil" toIbe retained on site to accomplish the proposed reclamation plan. This must <br />be completed prior to sale of topsoil acquired form the site. Please indicate when the appropriate soil <br />amendments needed for reclamation will be determined and how these amendments will be incorporated into <br />the permit. <br />The submitted reclamation planji and mining plan proposes to use construction debris as backfill. The <br />Reclamation Plan states that the Operator will comply with. the regulations regarding use of imported <br />materials for backfill. Please be aware that the proposed use of construction debris will fall under this <br />category and will require the Operator to comply with Rule 3.1.5(9) (Reclamation Measures -Material <br />Handling of the Construction Materials Rules and Regulations which states that if the operator intends to <br />backfill inert structural fill generated outside of the approved permit area, the operator must note the office <br />according to guidelines specified i'n this rule. <br />The responses submitted to this is"sue in the adequacy response are inadequate to fulfill the parameters of Rule <br />3.1.5(9) of the Rules and Regulates for the Extraction of Construction Materials. Although the Division <br />understands that submitting specific dates,. locations, and volumes of material is not realistic at this time, <br />Reasonable estimates for these. parameters will need to be submitted to be considered as part of this permit. If <br />no reasonable estimates for these+parameters can be submitted at this time, the use of construction debris as <br />backfill at the site will need to be handled as an unapproved portion of the permit and the procedures listed <br />under Rule 3.1.5(9) will need to be followed by the Operator when the time comes to incorporate debris as <br />backfill at the site. The operator~Ishould be aware, with regard to the disposal of concrete at the site, excess <br />iron (rebar, usually) should be removed and the concrete should be cured for at least 60 days prior to coming <br />into contact with ground water. ~Add~itionally, despite the Applicant's hesitation to commit to providing the <br />Division with signed affidavits regarding the materials acquired offsite for backfill, this will be a requirement <br />of the permit.. Please submit the requested information and a commitment to fulfill .the requirements <br />described above, or commit to the use of construction debris as backfill at the site as an unapproved portion of <br />the permit and a commitment to follow the procedures outlined in Rule 3:1..5(9). <br />S. Rule (2)(~(ii) of this Exhibit requires the Applicant to specify types, mixtures, quantities, and expected time(s) <br />of seeding and planting for reclamation. The Applicant states that seeding of the areas designated as <br />pastureland, will be determined at a later time. The Division requires a proposed seeding plan as part of the <br />permit for areas designated asi pastureland, or rangeland, as post-mining .land use. Therefore this <br />reclamation plan will require a proposed seed mix, seeding rate, fertilizing, and mulching for those areas <br />designated as pastureland. If the parameters related to reclamation for these areas change, a technical <br />revision will be required when the changed reclamation is incorporated at the site. <br />The Division does not accept the Applicant's statement that pastureland is essentially the same as cropland <br />with regard to reclamation specifications. Additionally, the Division will not accept a proposal for seeding of <br />a monocrop for pastureland. Thej;Division will accept, however, a commitment to seed with either of the seed <br />mixes supplied in Attachment 3','of the adequacy responise. Please specify which seed mix will be used to <br />reclaim the pastureland areas of the site. <br />