2017-05-25_PERMIT FILE - M2017009

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Exhibit 6.3.4,Exhibit D—Reclamation Plan 15)The Division has reviewed the reclamation cost estimate submitted.The backfilling and grading cost and topsoil replacement cost will depend on how you address the adequacy review items above.Also, please address the following issues: b. The reclamation plan and mining plan narrative indicate that it is not clear if groundwater will be exposed and fill the pit area. Based on the Division's knowledge of the area and of a nearby mine site, it is very likely the operator will encounter ground water at shallow depths likely near the 7 foot depth.The cost estimate submitted is based on the assumption that a ground water pond will be created. In order to address the financial liability associated with the exposure of groundwater,the operator must first obtain a permanent augmentation plan from the Office of the State Engineer(SEO)prior to exposing ground water or the permittee may post a bond to either: i.Option A: backfill the pit to at least two feet above the static ground water level. ii. Option B: install an impervious clay liner or slurry wall to isolate the pit from the ground water table. Either supply evidence a permanent plan for augmentation has been obtained for the exposure of groundwater or provide an estimated cost for either bonding for option A or B discussed above. Or,you may commit to not exposing groundwater until a permanent plan for augmentation has been obtained for the entire projected area of exposed groundwater. If the latter option is chosen please revise the mining plan with this commitment. iii.PVRE Response: We are currently in discussion concerning a permanent plan for augementation.To allow time to complete that plan,we are hereby committing not to exposing groundwater until a permanent plan for augmentation has been obtained for the entire projected area of exposed groundwater. iv. DRMS Response: PVRE has committed not to expose groundwater until a permanent plan for augmentation has been obtained for the entire projected area of exposed groundwater.Given this,the Division will place a stipulation to the approval of this application that PURE must submit evidence to the Division that a permanent plan for augmentation has been obtained prior to exposing groundwater. We acknowledge that a stipulation will be made requiring evidence of a permanent plan for augmentation prior to any exposure of groundwater. c. The reclamation plan indicates the entire pit area will have overburden and topsoil replaced.The cost estimate only estimates that cost to replace topsoil over 2.4 acres.Please revise the estimate for topsoil replacement to cover the entire 9.9 acre affected area with topsoil. v.PYRE Response: Assuming the pit's final disposition is a pond, it will be impossible to place overburden and topsoil on slopes under water.They will be placed around the perimeter and on any slope down to water's edge. Our estimate of that area is 2.4 acres.The cost estimated has been revised to include an increased depth of 17"(1.42')but does not reflect covering the entire 9.9 acres. I am also including a cost estimate showing top soil replacement for 9.9 acres but do not believe that will be the end result. vi. DRMS Response: The applicant has committed to not exposing groundwater until a permanent plan of augmentation has been obtained. Given this, a pond may not be created initially so the Division's cost estimate will include the cost of spreading topsoil and overburden over the entire 9.9 acres. Once the applicant has obtained a permanent plan of augmentation and a pond can be created,the applicant can request a surety reduction to reduce the amount of bond needed to only spread topsoil/overburden over the areas above the waterline.