_INSPECTION - C1980005 ‎(34)‎

• Permit No: C1980005
• IBM Index Class Name: INSPECTION
• Doc Name: Inspection Report
• Inspection Date: 7/15/2008
• Email Name: DTM
• Media Type: D
• Archive: No

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.
further work does not appear to be warranted. Previous drainage stabilization repairs on Channel PM-2 and PM-
23 segments in the Pecoco vicinity appear to have been effective.
(e) Minor channel erosion is still evident along a segment of PM-6 above Stock Pond T-32, upstream of the
riprapped section (see Photo 3978/GPS Feature#13). Stabilization is warranted, and the segment is
marked for repair on the 2008 Rill and Gully Survey Repair Map.
(f)Active rilling was not evident on the east side of PM-6, below Road F. Apparently, the rills were repaired or
have stabilized.
(g)Some rills with grass becoming established were noted in the PM-4 upper watershed, but areas of active
erosion that would warrant remedial measures were not observed.
Q)There is still an active gully below Road E1 that flows into the upper reach of Channel PM-22, from the south.
Source of concentrated flow to the gully appears to be from road runoff, and also from a cow trail along a
fenceline south of the gully. Remedial measures are warranted, and should include installation of water
bars at intervals across the road travel surface and adjacent graded strip, and across the cow trail, in
addition to gully repair.The feature is marked on the 2008 Rill and Gully Survey Map. See Photo 3960/GPS
Feature#4.
(k), (1), and (m)Gully erosion along Channel PM-10 was not observed; apparently previously repaired. The
formerly gullied tributary to PM-10 had been graded through the segment of concern, and TRM channel lining
had been installed last year. Grass had recently germinated along the repaired segment, and the installation
looks very good (Photo 3990). There was no hole observed in the reclaimed highwall area south of the gullied
tributary; apparently was previously repaired. Rills are marked for repair on the 2008 Rill and Gully Survey Map
in the recently reclaimed Solid Waste Disposal Site at the upper end of PM-10, but these rills are within the
waste disposal boundary that was excluded from the SL-3 release request area.
(n) Noxious and problem weeds continue to be present at relatively low levels, with high density patches in some
locations (a number of patches were noted during the SL-3 inspection, and several were marked on the GPS
map). Weeds that have historically been of concern and continue to be the focus of control efforts at Seneca II
include Canada thistle, houndstongue, whitetop, and Dalmation toadflax. Stock pond and sediment pond sites
with some additional moisture and disturbance from stock concentrations, as well as locations subject to repeat
disturbance for channel or gully repair are where patches of these species are most common, though scattered
patches are found even in well vegetated upland parcels. The operator's weed management program appears to
have been successful in reducing the densities of these species and minimizing expansion of populations, but
continued monitoring and treatment on an annual basis is necessary. In the last few years, annual brome
(cheatgrass)appears to have increased in abundance in some locations in the mine vicinity, and the 2007/2008
fall and spring appears to have been very conducive to cheatgrass germination and growth throughout the low to
mid elevations zones of northwest Colorado. One patch of high density cheatgrass (approximately 5 acres in
extent)was delineated on the GPS map, on the ridge northwest of Channel PM-8(GPS#22/Photo 3979). A
number of other such patches of similar extent or larger(up to approximately 10 or 15 acres)were observed in
other locations in the same general area, and various other sites within the bond release request area. Varying
densities of perennial species are present in the cheatgrass patches observed.We recommend the operator
amend the approved weed control plan to address more aggressive treatment measures for annual
brome in areas of significant infestation (including use of herbicides such as Plateau or Journey, in
accordance with applicable use restrictions,which can be applied at rates that will impact cheatgrass
germination and seedling growth,with minimal impact to established perennial vegetation).
(o) Rill erosion was not observed along South Road B, although a gully segment that warrants repair was
noted immediately adjacent to the road in one location. This is the lower end of the"healed gully" in
Photo 3972/GPS#33.
6