_INSPECTION - C1980005 (34) - Laserfiche WebLink

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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. problems noted in a few road locations. One concern was noted in regard to a stock pond located along an ephemeral swale in the"Wadge Pasture" area, near the 1, 2,11,12 section corner,which has not been approved as a permanent impoundment. Revegetated areas were largely stable, and dominated by desirable perennial vegetation supportive of the wildlife habitat/livestock grazing postmining land use. Generally, older reclaimed areas appeared to support somewhat higher levels of cover and production, with more recent reclamation exhibiting somewhat higher vegetative diversity. Noxious and undesirable weeds are an on-going concern, but it is obvious that the operator's management program is maintaining weed populations to tolerable levels, with no parcels observed where noxious species exhibit heavy cover over significant portions of the parcel. A few areas of minor gully erosion, ditch scour, and one small slump were observed within the bond release application area, and stabilization grading or other maintenance will be necessary. The slump and several of the gullies were delineated by the operator on the 2008 Rill and Gully Survey Map; some of the gullies and segments of scoured road ditches had not been identified on the Rill and Gully Survey Map. A number of larger weed patches that were observed and will need to be sprayed in accordance with the approved weed management plan were marked with the GPS and are noted in Attachment 2. The slump and erosional areas that warrant repair are addressed in more detail in later sections of this report, and several of the locations were marked with the GPS and noted in Attachment 2. There were no bare areas of significant extent where it appeared that topsoil quantity or quality was deficient, or where deleterious spoil chemical characteristics may have been present. Significant diversity in plant community types and vegetative structure has developed across the reclaimed landscape, likely as a result of many factors including differences in initial seeding mixes and soil handling practices, differing climatic conditions during critical periods, soil textural differences, relatively diverse topography, and management history. Major portions of the SL-3 application area have been subject to managed grazing by cattle for many years, with some of the most productive grassland and sagebrush/grass communities occurring in the"Wadge Pasture" area of BRB-2, which has the longest history of livestock grazing of any portion of the release request area. The reclaimed areas provide habitat during various periods of the year for a wide variety of wildlife. Species observed on the reclamation in the SL-3 application area during the inspection included mule deer, elk, white-tailed jackrabbits, marmots, sharptailed grouse, a variety of ground-nesting song birds, and a rattlesnake. General Bond Release Inspection Considerations During any bond release inspection/evaluation, the Division gives consideration to the four issues addressed here below. (1)Results of past monthly inspections— For Seneca II Mine, our inspection review extended back to the Phase 1 bond release inspection report for SL-1, which applied to all of the lands included in the SL-3 application, as well as additional lands that were not included in the SL-3.application. The SL-1 inspection report addressed "Pre-law" areas that were not included in the SL-3 application. In addition, the SL-1 inspection identified significant problems with drainage system stability in the"East Wadge Pit", PM-8 watershed. As a result, the 125.8 acre East Wadge Pit area of concern was delineated and excluded from the SL-1 Phase 1 bond release, and extensive drainage repair and stabilization work was subsequently performed in the watershed. The delineated East Wadge Pit area that was excluded from the Phase 1 bond release approval was not included in the SL-3 Phase II bond release application, and the East Wadge area is not addressed in this report, with respect to Phase II bond release evaluation. Various other permit area disturbances were excluded from the SL-3 application because reclamation has not yet been completed, or was only very recently completed (e.g. the shop facilities area, solid waste disposal area, and a narrow corridor of recent disturbance associated with Permanent Channel PM-12A). 4