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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 />Diversion and Collection Ditches and culverts in the waste disposal area were generally in good condition, with <br />the exception that large tumbleweeds have accumulated in several locations along the waste area upper <br />diversion ditch, and also at the inlet end of the haul road culvert immediately west of the sediment pond <br />embankment. Tumbleweed accumulations need to be cleared out of the waste disposal area ditches and <br />from in front of the haul road culvert near the sediment pond embankment. <br />Backfill and Grading <br />There was no evidence of erosion on the interim reclamation fill on the mine bench area, and no evidence of <br />renewed cracking, caving, or sloughing. <br />Processino Waste <br />Additional waste had recently been hauled from the pond sediment cleanout area at McClave Canyon Mine, and <br />placed in the excavated disposal cell at the waste disposal area. Some of the material had been graded, some <br />remained in loose dump piles. The material will need to be graded and compacted in maximum two foot lifts. <br />Grasses seeded on the refuse cover soil stockpile last summer have recently initiated spring growth. The cover <br />soil pile appears stable, with no evidence of slumping or rills and gullies. <br />Topsoil <br />The topsoil stockpiles on the lower road and at the waste disposal area, and the "dirt stockpile' on the mine <br />bench (which will be used as reclamation topdressing) are well vegetated and stable. <br />Reveoetation <br />Interim vegetation cover in the portal area and topsoil stockpiles near the refuse area and adjacent to the lower <br />road segment is well established and effective in most areas. The waste disposal cover soil stockpile was <br />seeded last summer, and grasses germinated in early fall. Those grasses have recently initiated spring growth, <br />and it appears that they will provide an effective cover within a few weeks. Stabilization seeding conducted <br />last year on the sediment pond embankment and berm, and areas immediately to the east of the waste <br />disposal cell appear to have been less successful. These areas may need to be reseeded in <br />conjunction with permanent reclamation/revegetation of the waste disposal area anticipated for this fall. <br />Whitetop weed was observed in various disturbed area locations, and spraying will be required during April, in <br />accordance with the weed control plan in the permit. Locations include the top of the soil stockpile on the mine <br />bench, waste area sediment pond embankment toward the south end, waste area cover soil stockpile upper <br />diversion, margins of the lower road topsoil stockpile, and various other locations. Patches of whitetop were <br />noted along the reclaimed drill site access road last year, and may warrant re-treatment this year. <br />At the reclaimed Loma Loadout, a relatively good vegetative cover has become established. Seeded perennial <br />grass (western wheatgrass) and the subshrub forage kochia have initiated spring growth, and appear healthy <br />and robust. Seeded shrubs four-wing saltbush and greasewood are present at modest densities, along with a <br />significant winter annual component (tumble mustard, blue mustard, annual brome, etc.). Cover on the <br />reclaimed area is comparable to immediately adjacent areas, with the exception that the perennial grass <br />component is higher on the reclaimed area. <br />4 <br />