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Jerry M. Nettleton <br />Page 11 <br />June 11, 2014 <br />19. Beginning on permit page 2.05 -31.1, MCM discusses some of the individual areas of the mine that <br />will be reclaimed. With the reclamation that was performed in 2008, 2009 and 2010, the status of <br />some of these areas has changed. These areas include changes to the wastewater facility, the old <br />shop area (Empire Village), the multiple services building and the miscellaneous areas. Please <br />update the reclamation status of the areas listed in the permit, beginning on page 2.05 -31.1, to <br />reflect the reclamation completed in 2008, 2009 and 2010. <br />a. MCM Response: The Permit discussion of reclamation activities has been reviewed and <br />updated, as appropriate, to reflect recent site demolition and reclamation activities. <br />Copies of the revised Permit discussion accompany these responses for replacement in <br />the PAP. <br />b. DRMS Response: This item is resolved. <br />20. Permit page 2.05 -32 contains the Williams Fork Mines ' `Noxious Weed Management Plan ". One of <br />the problems noted on the site in recent inspections is the Russian Knapweed infestation. The weed <br />management plan contains very little information regarding this noxious weed. There are also <br />scattered patches of hounds tongue on the site, mostly along the east side of the haul road and refuse <br />piles. There is no individual mention of the hounds tongue in the weed management plan, with the <br />exception of a statement that spraying for white top also addresses hounds tongue. Finally, based on <br />the weed spraying requirements of the past few years, it seems as though MCM may need to spray for <br />noxious weeds on multiple occasions in order to control them. Please review and amend the <br />Noxious Weed Management Plan to include more detailed information regarding the Russian <br />Knapweed infestation that has been noted at the Williams Fork Mines and the Williams Fork Strip <br />Pit and the hounds tongue that has been observed on the site. Please also amend the plan to <br />include more specific detail regarding the timing of the weed spraying and the need for multiple <br />weed spraying during a given season. <br />a. MCM responded to both items 20 and 21 below. <br />21. Permit page 2.05 -32a discusses the weed identification, mapping and tracking activities that are <br />associated with the noxious weed management plan. The text gives little detail regarding the method <br />of weed mapping and tracking. Currently, MCM provides some weed mapping and spraying detail <br />on their annual reclamation report map (Reclamation and Building Demolition Map). This map <br />provides unconnected information and the multiple colors and layers create problems in reading the <br />map. Please update the noxious weed management plan to include more detail regarding how <br />MCM performs their noxious weed mapping and tracking programs at the Williams Fork Mines <br />and the Williams Fork Strip Pit, including whether point or area features are mapped, what <br />constitutes a weed patch for mapping purposes, etc. Please add a commitment to the permit to <br />include a separate weed tracking map in the Annual Reclamation Report. This map should show <br />the weed species encountered, their location, the method of treatment and the initial year they were <br />seen at that location. The weed tracking layers can then be removed from the Reclamation and <br />Building Demolition Map currently included in the ARR (although this map, with the reclamation <br />information, will need to remain). <br />