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Nuvemco, LLC's Monogram Mine M-1978-222UG <br />Response to Preliminary Adequacy Review <br />March 10, 2009 <br />(e) DRMS recommends submitting a formal plan for the control of knapweed for the site. If in the future <br />knapweed is observed within or along toad ways or disturbances in the pen-nit area a technical Revision adding <br />in the plan will be required. <br />This weed control requirement is acknowledged. Operations at a nearby mining property (Last <br />Chance Mine) are covered by a BLM weed control plan. That plan or a similar DRMS and <br />Montrose County approved plan will be added with a Technical Revision should a knapweed <br />infestation be discovered. Nuvemco's Best Management Practices will aid in preventing the <br />introduction or spreading of noxious weeds. <br />(d) DRMS notes the area has limited cover. The general policy is for reclamation vegetation to be equal to or <br />better than sunvunding non-disturbed areas, A 40% cover criteria may be too rigid of a goal. Staff <br />recommends changing the wording to note that re-vegetation success will be equal to or better than the <br />surrounding area as determined by DBMS. <br />In accordance with the above comment from DRMS, Nuvemco seeks to modify paragraph (d) on <br />page E-4 of the application to: <br />(d) Re-vegetation Success Criteria. The pre-mine site is a highly disturbed area dominated by <br />pinyon/juniper/sage species with undergrowth of grasses and forbs. As seen in the aerial <br />photographic basemaps and on numerous photographs taken in the area, a significant portion of <br />the ground is barren rock or established roads and trails. Based upon this reconnaissance of the <br />area it is recommended that the post-mining vegetation success will be equal to or better than the <br />surrounding area as determined by DRMS. <br />Rule 3.1.5 Materials handling: <br />It is noted that grnding within the mine area, backftlling, drill hole sealing and slopes meet the requirements of <br />this rule. Please clarify how any materials found to be above background in the office / ore bin area will be <br />handled for final reclamation to meet Rule 3.1.5 (2) and (5). <br />As shown on the new map in Appendix A. Map 3. Monogram Staging Area Background <br />Radiometric Survey and in the Table A-I which follows it, the average background radiation in <br />the area is almost 2,000 cps. This is about ten times the barren rock background and comparable <br />to most surface mining areas on the mesa. Subsequent to reclaiming the Staging Area, Nuvemco <br />will conduct another close spaced radiometric survey with the same instruments to confirm no <br />increase in background. Highly radioactive rocks will be put in the ore pile for shipping, or <br />interred and disposed of with the ore bins and sump tanks. If required to lower the average <br />reclaimed background, Nuvemco will move some of the low count shales from elsewhere on the <br />permit to cover and stabilize the graded ground. <br />Rule 3.1.8 Wildlife <br />CDOW comments have been forwarded to Nuvemco with a request that any correspondence be copied the <br />Division for the permit file. Although big game habitat seems to be marginally impacted there appears to be an <br />issue with bats in historical mines. <br />12