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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 />and monitoring will be required, and new herbicides and herbicide combinations will be <br />employed. The weed control narrative in Tab 22 of the approved permit and herbicide <br />product listing (Table 22-81 should be amended to conform with the 2004 Seneca Mines <br />Noxious Weed Management Plan, as it applies to the Seneca II-W permit. This revision ' <br />could logically incorporate related concerns recently addressed by the Division in our <br />review of the 2003 annual reclamation report. <br />Seedbed preparation last fall on the steep broadcast seeded area at the west end of the <br />"D" Pit final highwall slope entailed extensive roughening. On page 12 of Tab 22 of the <br />approved permit application, narrative states that "...replaced soils on slopes steeper <br />than 25% will be pockmarked with dozer dips or track-hoe humps". The actual seedbed <br />preparation work was conducted in mid November after snowfall had created slippery <br />surface conditions on the steep slopes. The small dozer initially employed for the task <br />was unable to get adequate traction on the slope, and a D-8 was subsequently used. <br />The larger dozer was still unable to back up the slope to create "pocks" or "humps", <br />and ended up traversing the slope along the contour. The effect created was closely <br />spaced parallel swaths separated by ridges or windrows of deeper topsoil, roughly along <br />the contour. Erosion down the slope was effectively prevented, but there was some <br />evidence of minor rilling parallel to the windrows. The technique did not result in the <br />desired pocked or gouged effect, for enhanced water retention, seed catchment, and <br />seedling protection. The steep slope roughened seedbed area needs to be re-worked to <br />achieve the desired "pockmarked" effect. Broadcast seeding will need to be repeated <br />following the roughening treatment. <br />11 Page 22 of Permit Tab 22 narrative contains the following statement: <br />Concentrated shrub seeding wil/ be the preferred method of shrub estab/ilshment <br />based on existing monitoring results. Some species, however, will be introduced as <br />tubelings, i. e, gambel oak, aspen, and mountain mahogany that do not respond well <br />from direct seeding. Within the origins/ 11-W permit area, shrub seeded areas will be <br />approximately one to three acres in size and will primarily be scattered in the two <br />areas illustrated on Ezhibit 22-1 lin addition to the specified seedling planting areasl. <br />Exhibit 22-1 depicts two broad areas within which concentrated shrub seeding will be <br />conducted. Presumably, these areas would be seeded with Seed Mix 6, in contrast to <br />the surrounding areas seeded with Seed Mix 1. Seed Mix 6 contains only shrubs and <br />native forbs, whereas Seed Mix 1 contains numerous grasses and forbs, as well as three <br />shrub species (big sagebrush, snowberry, and bitterbrush). Exhibit 22-lalso depicts a <br />number of shrub seedling planting areas, that would be planted with specified planting <br />lists, and which presumably would also be seeded with Seed Mix 6. <br />Concentrated shrub seeding areas and numerous seedling planting areas are specified <br />for various portions of the "D" Pit that were topsoiled and seeded last fall, as well as <br />portions of the "A° Pit area that will be topsoiled and seeded this coming fall. Seedling <br />11 <br />