2017-11-21_REVISION - M1979094HR

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• to% cotter The associated stormwater management controls will be inspected and maintained, as necessary, to provide control of stormwater run-off as described in the Environmental Protection Plan ("EPP") for the JD-7 Mine, dated September 2012, attached as Exhibit U to Cotter's 112d Application Amendment ("Application Amendment") for the JD-7 Mine, dated September 2012. The EPP and Application Amendment also contain the measures to be taken to comply with reclamation requirements and/or other activities related to the performance standards of Section 3.1 of the Hard Rock/Metal Mining Rules, which will continue to be implemented during periods of temporary cessation and are incorporated by reference into this letter. The existing financial warranty of$1,676,584.00 held by the Division and the United States Department of Energy ("DOE") is adequate to cover the reclamation liability of the site as it exists today. See letter, dated March 30, 2015, from Cotter, to the Division (total financial warranty in place equals the financial warranty required by the Division). Reclamation activities that would be required at this time include removal of the office/dry building, removal of the shop building, closing of the portal, closing of the vent hole, reclaiming the mine de-watering ponds, re-contouring the mine waste material, and spreading the stockpiled topsoil over the required areas. These areas would then need to be seeded to promote re- vegetation of the site. The JD-7 Mine contains valuable mineral reserves that include, conservatively, millions of pounds of uranium and vanadium. See DOE, Final Uranium Leasing Program Programmatic Environmental Impact Statement(March 2014) ("Leasing PEIS"), at Table 1.3-1 (estimating 2.8 million pounds of uranium oxide in JD-7 lease tract); Findings of Fact, Conclusions of Law, and Order, In the Matter of Cotter Corporation (N.S.L.)'s Notices of Temporary Cessation (May 7, 2013), at¶ 57 ("[v]aluable mineral reserves" remain in the JD-7 Mine); letter, dated February 13, 1991, from Cotter, to the Division, at 3 (current mineral resources at the JD-7 Pit Mine are 623,700 tons with 100,000 tons of additional mineral resource expected to be discovered). Cotter's mine plan for mining such reserves is attached as Exhibit D to the JD-7 Application Amendment, and projects ten years will be required to extract all ore from the mine. JD-7 Application Amendment, Exhibit D, at D-2 to D-4. Cotter is committed to mining operations at the JD-7 Mine by the end of the second five-year period of temporary cessation (December 15, 2022). This commitment is demonstrated by the substantial resources it invested in preparing the JD-7 Mine's EPP, Drainage Design Plan, mine plan, reclamation plan and other studies; collecting geologic and environmental data; submitting the JD-7 Application Amendment to the Division; and obtaining the Division's approval of the JD-7 Application Amendment through the Division's rigorous adequacy review process. Cotter's commitment is also demonstrated by the ten-year lease, 2