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REV92776
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Last modified
8/25/2016 3:14:09 AM
Creation date
11/21/2007 11:24:27 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981018
IBM Index Class Name
Revision
Doc Date
5/1/1998
Doc Name
DESERADO MINE PN C-81-018 TR 48 MIDTERM REVIEW RESPONSES
From
DMG
To
WESTERN FUELS ASSOCIATION INC
Type & Sequence
TR48
Media Type
D
Archive
No
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1 I. DMG had recommended that the RP-I remedial seedmix and seeding methodology be <br />adopted for other refuse azeas (and possibly other reclamation areas). The operator has <br />not incorporated this recommendation at this time, but has indicated that various aspects <br />of the revegetation plan, including possible seedmix and seeding technique modifications, <br />and the assessment of the need for remedial treatments on previously revegetated areas <br />will be addressed following completion of revegetation monitoring and evaluation to be <br />conducted this summer. We consider this to be appropriate. The revegetation evaluation <br />and proposed revision to the revegetation plan will need to be submitted to the Division <br />as soon as possible following completion of monitoring, to allow for review and approval <br />prior to fall, 1998 revegetation efforts. <br />In addition to possible seedmix and seeding modifications, specific timeframes for <br />dormant season and spring seeding should be specified, straw or hay mulch application <br />rate of 2 tons per acre should be specified (unless justification for current 1 ton per acre <br />rate is provided), and consideration should be given to specifying use of certified weed <br />free mulch (this may be required by BLM). <br />l2. Operator has comitted to submittal of annual evaluation of permanent revegetated azeas <br />beginning with the 1998 Annual Reclamation Report. <br />l3. The Division's October 30, 1997, letter indicated that concems regarding success <br />standards, sampling techniques, and statistical formulas had been resolved. However, we <br />have identified certain additional concems following review of the amended revegetation <br />plan, which will need to be resolved: <br />a) The hypothesis testing described on page V-65, to compaze reference azeas to <br />NRCS range sites is not necessary. A species composition based evaluation of reference <br />areas (from statistically adequate data) would be sufficient to determine whether the <br />reference azea is in "fair" or better condition, based on NRCS criteria, and the operator <br />may want to consider this approach. <br />b) Rule 4.15.7(4) specifies two primary methods by which reference areas may be <br />utilized to determine revegetation success; comparison of individual reference areas to <br />specific corresponding plant communities on the reclaimed surface, or weighted average <br />comparison between all reference areas and the entire revegetated area, based on the <br />relative area occupied by each plant community in the premining surface. The text on <br />amended page V-66 references testing of "reference areas and their paired affected sites", <br />implying that the former method would be employed, but few details are provided. <br />Revegetation plan text and the DMG Findings Document reference three fenced reference <br />areas, 0110, 0140, and 0150 (big sagebrush-western wheatgrass, big sagebmsh- <br />greasewood, and Colorado wildrye, respectively). The revegetation plan includes two <br />basic, permanent seedmixes, (seedmix 1--juniper woodlands, mixed grass <br />uplands/sagebrush grass uplands, and seedmix 2--mixed grass lowlands and sagebrush <br />lowlands). <br />
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