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from the old NOl should be simply transferred to the new one and used against any new disturbances. If <br />you would like, I would be glad to walk the property with you. <br />Comment 6b: The Division is keenly aware of the concept that `future exploration cannot be <br />predicted". However, the Dit-ision is tasked by statute to ensure mining and prospecting related <br />disturbance is reclaimed to a beneficial nnse. Therefore, ive must understand the nature of such proposed <br />disturbance in order to estimate reclamation liability. Please commit to submitting an NOI modification <br />application iffuture exploration ar:tivities require the proposed program to expand. <br />Response: Agreed. I believe that the bond is appropriate for the work described in the NOI. <br />However, should, future exploration activities increase the amount disturbance, it is very important that <br />the bond amount be increased to insure that adequate funds are available for reclamation in the event that <br />it would be necessary for DRMS to complete the work. <br />Comment 7: Referring to the "Fluid Drilling " bo.r being checked in Application Item No. 111.4, page <br />3, please explain why no rand pits are anticipated <br />Response: The mud pits were left off for a reason. After discussions with the permitee and drillers, <br />it was decided that for the small diameter holes, there are certain advantages for using field tanks versus <br />using mid pits. As a result the use of mud pits is not anticipated. If you look over to the oil industry, <br />even the large drilling rigs are going to tanks on many of their sites. If the project would require the <br />drilling of deeper larger diameter holes, then mud pits and even larger ponds might be considered and <br />would require additional bonding. If it makes you feel better, you could add a mud pit. But, even if you <br />do, a pit sized at 3 feet by 5 feet (15 square feet) does not amount to much of a closure cost. I came off a <br />project where two labors reclaimed them by hand in a couple of hours. Using a tractor, the same work <br />can be done in a few minutes. <br />Comment S: Referring the statement in Application ltem No. 111.6.D, page 4, please be aware you are <br />limited to only 100 feet of new road, unless an NO! modification application is submitted and approved. <br />Response: I discussed the amount of new road with the applicant prior to submitting the application, <br />and once again following your comment. He feels that this amount of new road is sufficient for the level <br />of work he can anticipate, and if the project should expand and additional road is required, DRMS will be <br />notified and appropriate actions can be taken to assure reclamation requirements are met. Note that the <br />estimated one acre in Section III.G greatly exceeds the total square footage of disturbances specifically <br />addressed in that section. Even if a road were to exceed the estimate by a few feet, or if a drill pad should <br />become a little larger than anticipated, the total disturbed area would still be well below an acre, and <br />ample bond would remain to cover the extra work required for reclamation. <br />Comment 9: Referring to the "Adits" box being checked in Application Item No. 111.4, page 3, please <br />explain why no portals are anticipated. <br />Response: The adits box is checked because there can be old small open adits in within the <br />prospecting area and these openings can present a danger and liability. It is not the prospector's intention <br />to create new adits, but instead the intention of making them safe_ At this time, no specific openings have <br />been identified. If they are identified they should be handled in a manner that should make both DBMS <br />and the property owner happy. <br />