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Exhibit D 1
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Exhibit D 1
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Last modified
12/15/2025 11:52:49 AM
Creation date
12/15/2025 11:50:56 AM
Metadata
Fields
Template:
DRMS Permit Index
IBM Index Class Name
Revision
Doc Date
12/2/2025
From
QB
To
DRMS
Type & Sequence
TR18
Archive
No
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<br />24 | P a g e <br /> <br /> <br />4. Prescribe a Treatment <br /> <br />After the Weed Management Objective and Weed Management Area are <br />defined, QB and/or QB-hired contractors will assess and prescribe any <br />combination of the following post-emergent weed control methods: <br />• Cultural (see Section 4.1) <br />• Chemical (see Section 4.2) <br />• Mechanical (see Section 4.3) <br />• Biological (see Section 4.4) <br /> <br />4.1 Cultural Weed Management <br />QB has modified their operating culture to consider the prevention of weed seed <br />introduction, early detection/ rapid response (EDRR), rotation management, and <br />grazing monitoring & livestock management. <br />QB encourages all Third-Party companies and contractors to clean dirt-moving <br />equipment prior to mobilization into new areas, especially when equipment is <br />previously used in areas known to harbor infestations that do not currently exist <br />in the new area of disturbance. <br />To support rapid response, QB contracts with weed abatement contractors who <br />are on-call throughout the spring, summer and fall months. EHS Staff also carry <br />tools for mechanical weed removal, in the circumstance that a few, isolated <br />weeds are approached during regular field activities. <br />QB establishes treatment rotations on QB-managed properties to ensure that all <br />known infestations that exist on undisturbed areas are controlled. By keeping <br />weed infestations controlled on a landscape basis, the risk of spread onto <br />disturbed areas is reduced. A rotation system ensures that high visibility areas <br />are not the only areas treated; the more remote infestations are treated as well. <br />Due to the high level of livestock and wildlife in many of these remote areas, this <br />cultural practice reduces the spread of weed seed by animal vectors. <br />Lastly, livestock grazing plans, pasture rotations, pasture monitoring and <br />inventory plans are implemented to assess and minimize the impacts of grazing <br />on desirable, competitive plant communities. <br /> <br />4.2 Chemical Management <br />QB utilizes both pre-emergent and post-emergent chemical treatments for the <br />control of non-listed and noxious weed species. Chemical means of weed control <br />are the most commonly utilized weed management technique. The frequency of <br />this treatment method is mostly attributed to the financial feasibility, speed and <br />relative consistency in results associated with herbicide applications. In general, <br />most QB sites are inventoried, monitored and sprayed a minimum of 1-4 times <br />per year, based upon the accessibility and known infestation status of the site. <br />With every visit, commercial pesticide applicators monitor previous treatments for <br />effectiveness, inventory for new or surviving plants, and treat the site. <br />Documentation of this event is recorded into QB’ data management system <br />(ACTS) as reported on contractor invoices and daily pesticide application records <br />(PARs). <br />For all chemical treatments within reclamation areas, care is taken to prevent <br />degradation of desirable plant communities. Only spot -specific herbicide
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