2010-05-10_GENERAL DOCUMENTS - C1981019

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the final topography or post-mining drainage of the Section 16 Pit are necessary a revision to the permit will be required. Rule 4.15 - Revegetation 24. Pursuant to Rule 4.15.1(5) all operators are required to have a detailed weed management plan in their permit. Colowyo originally submitted an approved weed management plan with the submittal of Minor Revision 81. This plan, however, appears to have been removed from the permit during the Technical Revision 72 permitting process. Colowyo will need to add this weed control plan back into the permit immediately (through a technical revision). In addition to resubmitting the plan that was previously approved with Minor Revision 81, there are several other areas of concern regarding weed control at the Colowyo Mine have come up that will also need to be addressed. First, there appears to be a growing cheatgrass problem in the East Pit at the Colowyo Mine (no pun intended). This conclusion is based on both yearly vegetation monitoring reports contained in the Colowyo Annual Reclamation Report as well as on the ground verification from monthly inspections. Colowyo will need to include a comprehensive cheatgrass identification and control plan in the weed control plan. This plan will need to include, at a minimum, identification of affected areas (surveying), chemicals to be used on the cheatgrass, timing of spraying, determination of the success of the spraying and a plan for determining if the treatment was successful or if an area needs to be resprayed the following year(s). Second, in discussing weed related issues with the Colowyo staff it has become apparent that besides the fact that Colowyo hires and pays a contractor to spray for weeds every year at the mine, there is no data on what weeds were encountered or where those weeds were encountered. In 2009 there were numerous areas that had large patches of bull and musk thistle that were either not sprayed, were not killed by spraying (wrong herbicide?) or were late emerging (the lower Prospect watershed and West Pit Fill, for example). Without this information on how and where the weeds were sprayed it was impossible to determine what happened. Colowyo will need to implement a plan that documents the species of weeds encountered, the location of the weeds and the chemical(s) used to treat the weeds. This information will need to be reported in the Annual Reclamation Report and shown on a map or plate within the report. Colowyo will also need to have information to document that the entire reclaimed area was surveyed and sprayed as necessary. Third, Colowyo will need to include a plan for spraying or respraying weeds that are either missed by the contractor, do not die on the initial spraying or are late emerging, as they are found during field inspections. Colowyo Mine Permit No. C-1981-019 2010 Midterm Review 10 May 2010 15