|
III. COMMENTS -COMPLIANCE
<br />Below are comments on the inspection. The comments include discussion of observations made
<br />during the inspection. Comments also describe any enforcement actions taken during the inspection
<br />and the facts or evidence supporting the enforcement action.
<br />General Comments
<br />This was a partial mine site inspection focusing on vegetation establishment and vegetation monitoring,
<br />conducted by Dan Mathews of the DMG Grand Junction Field Office. Roy Karo of Seneca Coal Company
<br />was contacted during the inspection and at the conclusion of the inspection, but he was not present
<br />during the field inspection. Dr. David Buckner and his employees with ESCO Associates were on site
<br />conducting the annual vegetation monitoring of revegetated stands and reference areas, and some time
<br />was spent each day observing the sampling procedures. In addition, detailed observations were
<br />conducted within recently revegetated portions of the lower "A" Pit and "B" Pit reclamation areas.
<br />Vegetation Sampling Observations
<br />The operator conducts vegetation monitoring (cover, production, species presence/density, and woody
<br />plant density) on an annual basis at Seneca II-W. Monitoring is conducted within 2ntl year, 4`" year, and
<br />7`" year reclaimed stands each year, and most years, monitoring is also conducted within the extended
<br />reference areas. The monitoring has been conducted for the life of the mine, and an extensive data base
<br />has been accumulated, which allows for assessment of trends over time. Standardized data collection
<br />methods and presentation approaches are used, and data presentation, summary, and assessment is
<br />presented in an annual revegetation report.
<br />On the morning of July 27, I joined two ESCO employees, Margaret and Jim, who were collecting cover
<br />and species presence/density data within a 1998 or 1999 seeded parcel (7`" or 6`" year stand) in the "C"
<br />Pit area in the upper 005 Gulch watershed. [Note, there was a discrepancy between the Annual
<br />Reclamation Report Map which showed the parcel as "1999-74.2 ac." and the map the samplers had,
<br />which showed the area as a 1998 seeded parcel. This discrepancy will need to be resolved and
<br />corrected in the 2004 reclamation map or the 2005 reclamation map, as warranted.] The transect start
<br />points had been randomly located and plotted on a reclamation map, and were located in the field using a
<br />GPS unit. Herbaceous production and woody plant density data had been collected at these same
<br />transect locations the previous day. Cover readings were taken using a tripod mounted, telescopic site
<br />type ocular point bar, developed and marketed by ESCO Associates. The tripod was set up at one meter
<br />intervals along a 50m transect, with two readings taken per set-up (cover bar rotated 180 degrees to
<br />allow for second reading), resulting in 100 cover readings per transect. Readings were recorded by
<br />species acronym Ifor hits on current year vegetation growth), or as bare, litter, soil, or standing dead.
<br />Margaret had abotany/agronomy background, and was able to identify most of the species encountered.
<br />She collected sample specimens for species she was uncertain about, for later key-out or confirmation by
<br />Dr. Buckner. Species presence data was collected by listing all additional species occurring within a 1
<br />meter wide belt on either side of the transect tape (that had not been "hit" during cover sampling). This
<br />allows for the construction of a species list for the sampled parcel, and also allows for the determination
<br />of species density (number of species per 100 square meters) for each transect. Average species density
<br />for a parcel is presented in the annual report, as a measure of species richness.
<br />The parcel being sampled seemed to be a diverse stand dominated by native perennial grasses and native
<br />and introduced perennial forbs, with a somewhat higher annual component than might normally be
<br />expected for a stand of this age. Annuals included Japanese brome, Sisymbrium mustard, and various
<br />other annual forbs. The relatively high abundance of annuals is likely associated with above normal
<br />precipitation in the fall of 2004 and spring of 2005. There were moderate numbers of big sagebrush,
<br />snowberry, and rubber rabbitbrush shrubs, and a scattering of Canada thistle and houndstongue noxious
<br />weeds. Perennial grasses included western wheatgrass, slender wheatgrass, beardless bluebunch, basin
<br />wildrye, mountain brome, Canada bluegrass, Kentucky bluegrass, orchardgrass, and various others.
<br />
|