2014-07-16_REVISION - C1981044 - Laserfiche WebLink

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multiple services building and the miscellaneous areas. Please update the reclamation status of the areas listed in the permit, beginning on page 2.05 -31.1, to reflect the reclamation completed in 2008, 2009 and 2010. a. MCM Response: The Permit discussion of reclamation activities has been reviewed and updated, as appropriate, to reflect recent site demolition and reclamation activities. Copies of the revised Permit discussion accompany these responses for replacement in the PAP. b. DRMS Response: This item is resolved. 20. Permit page 2.05 -32 contains the Williams Fork Mines' "Noxious Weed Management Plan". One of the problems noted on the site in recent inspections is the Russian Knapweed infestation. The weed management plan contains very little information regarding this noxious weed. There are also scattered patches of hounds tongue on the site, mostly along the east side of the haul road and refuse piles. There is no individual mention of the hounds tongue in the weed management plan, with the exception of a statement that spraying for white top also addresses hounds tongue. Finally, based on the weed spraying requirements of the past few years, it seems as though MCM may need to spray for noxious weeds on multiple occasions in order to control them. Please review and amend the Noxious Weed Management Plan to include more detailed information regarding the Russian Knapweed infestation that has been noted at the Williams Fork Mines and the Williams Fork Strip Pit and the houndstongue that has been observed on the site. Please also amend the plan to include more specific detail regarding the timing of the weed spraying and the need for multiple weed spraying during a given season. a. MCM responded to both items 20 and 21 below. 21. Permit page 2.05 -32a discusses the weed identification, mapping and tracking activities that are associated with the noxious weed management plan. The text gives little detail regarding the method of weed mapping and tracking. Currently, MCM provides some weed mapping and spraying detail on their annual reclamation report map (Reclamation and Building Demolition Map). This map provides unconnected information and the multiple colors and layers create problems in reading the map. Please update the noxious weed management plan to include more detail regarding how MCM performs their noxious weed mapping and tracking programs at the Williams Fork Mines and the Williams Fork Strip Pit, including whether point or area features are mapped, what constitutes a weed patch for mapping purposes, etc. Please add a commitment to the permit to include a separate weed tracking map in the Annual Reclamation Report. This map should show the weed species encountered, their location, the method of treatment and the initial year they were seen at that location. The weed tracking layers can then be removed from the Reclamation and Building Demolition Map currently included in the ARR (although this map, with the reclamation information, will need to remain). a. MCM Response: The specific Permit text discussion for the Noxious Weed Management Plan has been reviewed and revised, as appropriate to address the CDRMS's expressed concerns. MCM completes an annual noxious weed assessment, and then ties weed control activities during the year to the results of that assessment. Spraying typically takes place during spring and fall, targeting different weed species. Weed mapping has been included on the Reclamation and Building Demolition Map for convenience, and so that all relevant maintenance and reclamation information is provided in a consistent, concise format. MCM will work with the CDRMS to either modify this map to address the CDRMS's concerns or will create a separate map. Copies of the revised Permit discussion accompany these responses for replacement in the PAP. b. DBMS Response: MCM added Houndstongue to the list of species to be treated in the permit. The Division reviewed the 2013 Annual Reclamation Report submitted by MCM and it appears weed species and control methods are discussed in the narrative of the report. The Reclamation and Building Demolition Map submitted with the report delineates areas where specific herbicides were used but does not indicate where specific species are encountered. Revised page 5.05 -32.1 indicates the MCM maintains a working weed program map and records both observed weed occurrences by weed species, location, and extent of infestations; and treatment activities. Since this information exists, it should be added to the Reclamation and Building Demolition Map submitted in the Annual Reclamation Report.