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