INSPEC30172

• Permit No: C1981041
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 3/19/2007
• Email Name: DTM
• Media Type: D
• Archive: No

III. COMMENTS -COMPLIANCE
Below are comments on the inspection. The comments include discussion of observations made
during the inspection. Comments also describe any enforcement actions taken during the inspection
and the facts or evidence supporting the enforcement action.
segment had been largely completed by the time the field inspection was concluded on the evening of March 21
On both segments, a channel was excavated to the toe of the steep outlet slope, a fabric underliner was
installed, and the channel segments were lined with large sandstone riprap, set firmly in place with the track-hoe
Suooort Facilities
The Division previously approved a technical revision application to allow use of the rail loadout by another entity
for storage, loading and unloading of specified materials. This use has not yet been implemented; there has
been no resumption of activity at the loadout.
RevegetationlReclamation Success
North Decline Area
The North Decline reclaimed area was sprayed in November 2005 with "Plateau" and "Roundup" herbicides to
control cheatgrass, which dominated the vegetative understory to the exclusion of perennial herbaceous
species. A follow-up "Plateau" herbicide treatment was applied in September 2006, and interseeding was
conducted in February 2007. Soil scarification by was accomplished by ATV mounted spike tooth harrow, with
minimal damage to the mature shrub overstory. Herbicide treatments over the last lwo years have very
appreciably suppressed cheatgrass and other winter annuals, although growth of the target species has not
been entirely eliminated. Residual density of winter annuals varies across the site, generally higher density to
the north of the permanent channel. Operator is planning to apply one additional Round-up herbicide treatment
prior to the end of March, within select locations where density of annuals is relatively high, and density of
desirable shrubs is low.
General
A significant acreage was reclaimed and permanently seeded within various locations in 2002. Cover and
species composition of these sites were quantitatively monitored and compared to pertinent success criteria
during the 2006 growing season by Cedar Creek Associates, Inc. The associated vegetation report was
included in the 2006 Annual Reclamation Report. The report generally confirms qualitative observations,
indicating that, in many of the individual site locations, revegetated stands are lacking in one or more
components required for conformance with the diversity standard (cool season grass, warm season grass, or
perennial forb/half-shrub, depending on area). Heavy growth of winter annuals, primarily cheatgrass, along with
annual wheatgrass, annual barley, and stork's bill was documented in a number of locations. As noted in the
report, herbicide application to control annuals, combined with interseeding of select species depending on
deficient components in various locations, may be warranted. Operator may wish to delay development of re-
treatment plans for these areas, pending initial assessment of North Decline cheatgrass treatmenUinterseeding
results following the 2007 growing season.
One recommendation we would make, is that any future reclamation project that will involve the use of
topsoil or growth medium with a cheatgrass seedbank, should include incorporation of "Plateau"
herbicide or comparable product as a component of the initial revegetation plan.
Remnant whitetop weed patches were noted in a few locations that were sprayed in the past and will
require spraying again this April (e.g. RSRDA borrow, truck scale, north end of tamarix control area, lower
end of reclaimed South Fan road, North Portal silt fence).
4