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t <br />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 />This was a partial inspection of the New Horizon Mine, conducted by Dan Mathews of the DMG Grand <br />Junction Field Office, 101 South 3rtl, Suite 301, Grand Junction, CO 81501. Weather was clear and <br />warm. The focus of the inspection was on dryland pasture bond release vegetation sampling, which was <br />just getting under way for this year. <br />Sampling and Statistical Success Demonstration Procedural Clarifications <br />I met Mine Engineer Tony Adkins of WFC at the mine office to start the inspection, along with vegetation <br />consultant Steve Boyle and his associate Jim LeFevre, of BIO-Logic Environmental. We discussed some <br />questions Steve had regarding sampling and statistical testing procedures specified in the approved <br />permit application before we left the office. The sample adequacy formula in the permit is more stringent <br />than the formula that is included in the rule change package recently approved by OSM, and anticipated <br />to be approved by the MLRB at their September meeting. I recommended that WFC submit a technical <br />revision application to replace the current formula with the formula specified in the amended rules. I also <br />recommended that the sampling and success testing section of the reclamation plan be amended to <br />clarify procedures for drying production samples, and to provide more flexibility with respect to <br />production quadrat size and hypothesis testing options (consistent with amended regulatory provisions). <br />Dryland Pasture Reclamation Parcel Observations <br />The entire group proceeded to the mine reclamation areas that will be sampled. The first parcel viewed <br />was a dry pasture area in the NH-2 mine area, that is in Year 9, so this year will be the initial year of <br />bond release sampling for the parcel. The pasture is dominated by Russian wildrye; alfalfa is also a <br />significant component. Both species are included in the approved dry pasture seedmix. There was a <br />modest component of weedy annuals, and considerable bare ground between grass clumps, but there <br />was no indication of excessive erosion. <br />The second area viewed is referred to as the Rice tract. There is a small (10 acre) area at the north end <br />of the tract that is in Year 10, and a larger, (55 acre) parcel in the remainder of the tract that is in Year 9. <br />Most of this area is dominated by relatively sparse clumps of Russian wildrye. Despite a significant bare <br />ground component, no rills or gullies were observed. The operator indicated that there is significant <br />winter use of the area by elk, and that trespass use by cattle has also been a problem. <br />We observed a more recently revegetated dryland pasture area from the road that had been seeded within <br />the last year or two. The site had been irrigated for initial establishment, as is the common practice at <br />the mine, and the field had the appearance of a highly productive irrigated alfalfa/grass crop field. It is <br />possible that application of high levels of irrigation water during the initial establishment years may be <br />detrimental to the ultimate establishment of a mix of species adapted to the relatively low precipitation <br />levels that are typical in the mine area. The operator may want to consider irrigation of dryland sites on a <br />more limited basis, at levels that more closely approximate "normal" growing season precipitation. <br />Reference Area Sampling <br />After observing the reclaimed parcels to be sampled, I accompanied Steve Boyle and Jim LeFevre to the <br />dry pasture reference area, within the fenced area on the airport property south of the mine. There was a <br />heavy growth of Sisymb~ium mustard in the reference area, due to the above normal early spring moisture <br />this year. The annual mustard growth at this time consists of standing dead stalks and branches. The <br />dominant perennial plant in the reference area appears to be low growing scarlet globemallow, with <br />widely spaced clumps of Russian wildrye. It appears that there may have been some die-off of the <br />wildrye in recent years (based on dead plant bases present in the area), possibly due to the series of <br />