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the areas, anticipated tine frame for repair of any areas identified but not repaired, and <br />description of any re-topsoiling and re-seeding activities undertaken, or planned to be <br />undertaken. An inspection specific to identifying rills and gullies will occur in conjunction <br />with the spring stormwater management inspection of ditches, etc. Areas of concern will <br />be added to an internal list of locations requiring attention and the appropriated <br />manpower and equipment will be assigned to repair these locations as soon as possible <br />after they are identified. <br />23. Colowyo is currently placing South Taylor box-cut overburden material in the final cut of <br />the Section 16 Pit. The material is being used to backfill the pit to the approved final <br />topography, as shown of Map 19 and Map 19B. If any changes to the final topography or <br />post-mining drainage of the Section 16 Pit are necessary a revision to the permit will be <br />required. <br />Colowyo's Response: <br />In due course, Colowyo will be submitting updated materials that incorporate anticipated <br />changes in PMT, post-mining drainages, ditch design and configuration, etc. <br />Rule 4.15 - Revegetation <br />24. Pursuant to Rule 4.15.1(5) all operators are required to have a detailed weed management <br />plan in their permit. Colowyo originally submitted an approved weed management plan <br />with the submittal of Minor Revision 81. This plan, however, appears to have been <br />removed from the permit during the Technical Revision 72 permitting process. Colowyo <br />will need to add this weed control plan back into the permit immediately (through a <br />technical revision). In addition to resubmitting the plan that was previously approved with <br />Minor Revision 81, there are several other areas of concern regarding weed control at the <br />Colowyo Mine have come up that will also need to be addressed. <br />First, there appears to be a growing cheatgrass problem in the East Pit at the Colowyo <br />Mine (no pun intended). This conclusion is based on both yearly vegetation monitoring <br />reports contained in the Colowyo Annual Reclamation Report as well as on the ground <br />verification from monthly inspections. Colowyo will need to include a comprehensive <br />cheatgrass identification and control plan in the weed control plan. This plan will need to <br />include, at a minimum, identification of affected areas (surveying), chemicals to be used <br />on the 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 resprayed <br />the following year(s). <br />Second, in discussing weed related issues with the Colowyo staff it has become apparent <br />that besides the fact that Colowyo hires and pays a contractor to spray for weeds every <br />year at the mine, there is no data on what weeds were encountered or where those weeds <br />were encountered. In 2009 there were numerous areas that had large patches of bull and <br />music thistle that were either not sprayed, were not killed by spraying (wrong herbicide?) <br />or were late emerging (the lower Prospect watershed and West Pit Fill, for example). <br />Without this 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 documents the <br />species of weeds encountered, the location of the weeds and the chemical(s) used to treat <br />the weeds. This information will need to be reported in the Annual Reclamation Report <br />and shown on a map or plate within the report. Colowyo will also need to have