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,,. crpRUs Orchard Valley July 1, 1991 Mr. Randall P. Price Reclamation Specialist Colorado Mined lard Reclamation Division 215 Centennial Building 1313 Sherman Street Denver, ~ 80203 iii iiiiiiiiiiiuiii 999 Cyprus Orchard Valley Mine P. O. Box 1299 Paonia, "CRO~8142~ ~e ~G~p Fax ne: 3[~rS ~ I Rf ~ 4J' JUL 0 3 1991 Mined Land Reclamation Division RE: PEHI~tI'i' N0. C-81-038, 1991 CANADA 'IS-IISPLE O~TIROL PROGE2AM Dear Mr. Price: Zhis letter is submitted in order to clarify Cyprus Orchani Valley Coal Corporation's (COVCC) intentions with regani to weed wntrol efforts during the 1991 calendar year. Minor revision 68, approved June 5, 1990, calls for 00VCC to utilize herbicides on an as needed basis to control noxious weeds. In 1990, initial efforts to control Canada 'thistle encroachment an mine properties were conducted in early summer with the knowledge that an effective control program would need to continue for several seasons. 4he 1990 spraYin4 Prvgr"am aPPeared to produce good results with the above~rourri portions of individual plants observed to wither and die. Following the initial spraying, the contractor was called upon to return to the site to spray plants that had either been missed or had sprouted in the interim. `Ihe wntractor, Vic Eaton of Pest-Away Spraying, Delta, Colorado, indicated his suspicion that the designated herbicide mixture could be too "hot" and result in the destruction of the vegetative portion of the plants without allowing enough herbicide to be absorbed into the root system to actually kill the plants. Mr. Eaton's suspicion was apparently correct with the results evident as a discernible increase in Canada Zhistle population in the spring of 1991. In developing plans for the 1991 spraying program, further conversations with Mr. Eaton led to the conclusion that 7brdon would provide a more effective, cost efficient control than the previously utilized Banvel mixture. 'Ihe Division was contacted by telephone on June 13 and 14, 1991, with regard to the appropriateness of utilizing Tordon. Randall Price and Zbny Waldron were consulted and concluded Tordon was acceptable but cautioned appropriate application guidelines be strictly observed given 4lordon's more persistent nature. NVCC is confident that Mr. Eaton p~raacaa the requisite expertise to safely utilize this product.