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mountainous area. Access is limited and the terrain is steep and inhospitable. Having reclaimed slope faces that <br />exceed 3h : 1 v will not have a negative impact to the vicinity, either structurally or visibly. <br />Further downgradient of the Tailings Impoundment, Hukill Gulch becomes even more steep and inaccessible. The <br />Colorado School of Mines owns over a dozen properties in this vicinity; one of which, the Edgar Union Lode, <br />contains three large dumps that are 350' downgrade from the proposed Tailings Impoundment. <br />This operation fits into the local land use, both during and after the reclamation measures have been applied post- <br />operations. <br />6.3.4(1)(c)(i) <br />Venture Resources has sought the advice of the Natural Resources Conservation Service (MRCS) for guidance in <br />specifying a reclamation soil and seeding plan. The NRCS has provided their recommendations in a letter that has <br />been attached to the appendix of this Exhibit D. <br />As stated in the Mining Plan Exhibit C - 6.3.3(1)(b) and considering the nature of poor topsoil conditions at this site <br />(0-2" Cathedral soil and virtually no accumulation of true A horizon topsoil, as previously described in Exhibit B) it <br />will be challenging to salvage any significant quantities for future reclamation uses. Additionally, over 30% of the <br />impoundment area is currently covered with existing waste rock. Venture Resources is going to do our best in <br />salvaging any native, Cathedral soil (also any A, AB, and Bw horizon soil) for reclamation. Blending of these <br />different soils is also permitted. It will be very likely that soil will need to be imported. <br />Reclaimed or imported topsoil shall be applied over the uncapped tailings for a depth of 6 inches. NRCS states that <br />the available water holding capacity of the Cathedral soil is 0.06-0.07 inches/inch (i.e. 6 inches of Cathedral soil <br />can store approximately 0.4 inch of water). The tailings will also provide for some moisture storage. During the <br />growing season in this vicinity there will be about 7 inches of precipitation. NRCS states that most commercially <br />available grass species require 10 to 14 inches of precipitation. Inorder to improve the soil's water holding capacity, <br />organic matter will need to be added and to the soil. The NRCS strongly recommends the application of certified <br />weed flee straw (applied at 2 tons per acre) covered with bio-degradable netting or application of wood cellulose <br />hydro mulch with a long-lived tackifier. Additionally, the application of geosynthetic reinforcing, namely Synteen <br />Technical Fabrics SF 20 Geogrid (or equal), shall be utilized as sub-grade stabilization on the embankment face <br />prior to applying reclamation soil. Temporary erosion control measures shall be implemented around this area <br />during this activity (ie silt fence, straw bales, see SWMP). <br />An alternate method of preparing the topsoil utilizing Class A biosolids may also be used. The DRMS has stated <br />that amending the salvaged topsoil with Class A biosolids to achieve three percent, 3%, organic content will provide <br />for "superior plant growth medium". Soil testing shall be conducted to verify this percentage. Class A biosolids <br />shall be incorporated at a rate of forty tons per acre. The NRCS recommendation of applying certified weed free <br />straw (applied at 2 tons per acre) covered with bio-degradable netting or application of wood cellulose hydro mulch <br />with a long-lived tackifier shall also be followed with this alternate method. <br />The tailings are already pH conditioned, to a value ranging 7.5-9, as per the milling process by the addition of time. <br />6.3.4(1)(c)(ii) <br />Phased reclamation shall be part of normal operations. <br />Permanent reclamation and control measures will be installed in 10 feet phased increments (elevation height of one <br />quarter of a terrace) which is estimated to occur every several months. The application of geosynthetic reinforcing, <br />namely Synteen Technical Fabrics SF 20 Geogrid (or equal), shall be utilized as sub-grade stabilization on the <br />embankment face prior to applying reclamation soil. Seeding will occur to coincide with the appropriate time of <br />year for proper germination, whether it is closer to spring or fall season. Additionally, as each 40' high terrace is <br />completed, the exposed surface of the terrace will be re-vegetated as described above. <br />Previously seeded areas will be examined the following growing season to evaluate the success of the revegetation <br />efforts. Re-seeding shall be done if this previous seeding failed or is insufficient. <br />Page 3 of 9