2010-07-27_PERMIT FILE - M2009076 ‎(16)‎

• Permit No: M2009076
• IBM Index Class Name: PERMIT FILE
• Doc Date: 7/27/2010
• Doc Name: Adequacy Responses- Ex. D Reclamation Plan
• From: Venture Resources
• To: DRMS
• Email Name: ACS
• Media Type: D
• Archive: No

• impoundment, only to be enhanced by the reclamation and re-vegetation measures to be applied. Refer to Exhibit C
for more detail on impoundment construction.
It shall be noted that the natural grade in this vicinity averages 3h : lv. As previously stated at the opening of this
Exhibit in Post Mining Land Use Sunnnarv, the vicinity of the Tailings Impoundment is a remote, unpopulated
mountainous area. Access is limited and the terrain is steep and inhospitable. Having reclaimed slope faces that
exceed 3h : Iv will not have a negative impact to the vicinity, either structurally or visibly.
Further downgradient of the Tailings Impoundment, Hukill Gulch becomes even more steep and inaccessible. The
Colorado School of Mines owns over a dozen properties in this vicinity; one of which, the Edgar Union Lode,
contains three large dumps that are 350' downgrade from the proposed Tailings Impoundment.
This operation fits into the local land use, both during and after the reclamation measures have been applied post-
operations.
6.3.4(1)(c)(i)
Venture Resources has sought the advice of the Natural Resources Conservation Service (NRCS) for guidance in
specifying a. reclamation soil and seeding plan. The NRCS has provided their recommendations in a letter that has
been attached to the appendix of this Exhibit D.
As stated in the Mining Plan Exhibit C - 6.3.3(l)(b) and considering the nature of poor topsoil conditions at this site
(0-2" Cathedral soil and virtually no accumulation of true A horizon topsoil, as previously described in Exhibit B) it
will be challenging to salvage any significant quantities for future reclamation uses. Additionally, over 30% of the
impoundment area is currently covered with existing waste rock. Venture Resources is going to do our best in
salvaging any native, Cathedral soil for reclamation. NRCS recommends removing the pre-existing waste rock
down to native soil and then salvaging the first 3 inches of this native soil. This will be stored for later use in the
Topsoil/Biosolids Staging Area shown in the Exhibit .E drawings. It will be very likely that soil will need to be
imported.
Reclaimed or imported topsoil shall be applied over the uncapped tailings for a depth of 6 inches. NRCS states that
the available water holding capacity of the Cathedral soil is 0.06-0.07 inches/inch (i.e. 6 inches of Cathedral soil
can store approximately 0.4 inch of water). The tailings will also provide for some moisture storage. During the
growing season in this vicinity there will be about 7 inches of precipitation. NRCS states that most commercially
available grass species require 1.0 to 1.4 inches of precipitation. Inorder to improve the soil's water holding capacity,
organic matter will need to be added and to the soil. The NRCS strongly recommends the application of certified
weed free straw (applied at 2 tons per acre) covered with bio-degradable netting or application of wood cellulose
hydro mulch with a long-lived tackifier. Temporary erosion control measures shall be implemented aromid this area
during this activity (ie silt fence, straw bales, see SWMP).
An alternate method of preparing the topsoil utilizing Class A biosolids may also be used. The DRMS has stated
that aunending the salvaged topsoil with Class A biosolids to achieve three percent, 3%, organic content will provide
for "superior plant growth medium". Soil testing shall be conducted to verify this percentage. Class A biosolids
shall be incorporated at a rate of fort), tons per acre. The NRCS recommendation of applying certified weed free
straw (applied at 2 tons per acre) covered with bio-degradable netting or application of wood cellulose hydro mulch
with a long-lived tackifier shall also be followed with this alternate method.
The tailings are already pH conditioned, to a value ranging 7.5-9, as per the milling process by the addition of lime.
6.3.4(1)(c)(H)
Phased reclamation shall be part of normal operations.
Permanent reclamation and control measures will be installed in 10 feet phased increments (elevation height of one
quarter of a terrace) which is estimated to occur every several months. Seeding will occur to coincide with the
appropriate time of year for proper germination, whether it is closer to spring or fall season. Additionally, as each
• 40' high terrace is completed, the exposed surface of the terrace will be re-vegetated as described above.
Page 3 of 9