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• <br /> � <br /> % <br /> cotter <br /> Interim surveillance and maintenance will be conducted to keep the associated stormwater <br /> management controls working effectively as described in the Environmental Protection Plan <br /> ("EPP") for the JD-9 Mine, dated September 2012, attached as Exhibit U to Cotter's 112d <br /> Application Amendment("Application Amendment") for the JD-9 Mine, dated September <br /> 2012. The EPP and Application Amendment also contain the measures to be taken to <br /> comply with reclamation requirements and/or other activities related to the performance <br /> standards of Section 3.1 of the Hard Rock/Metal Mining Rules, which will continue to be <br /> implemented during periods of temporary cessation and are incorporated by reference into <br /> this letter. <br /> The existing financial warranty of$219,050.00 held by the Division and the United States <br /> Department of Energy("DOE") is adequate to cover the reclamation liability of the site at <br /> this time. See letter, dated March 30, 2015, from Cotter, to the Division (total financial <br /> warranty in place exceeds financial warranty required by the Division). Reclamation <br /> activities that would be required at this time include removal of the office/dry building, <br /> closing of the portal, closing of the three vent holes, re-contouring the mine waste material, <br /> and reclaiming the mine de-watering ponds. These areas would then need to be seeded to <br /> promote re-vegetation of the site. <br /> The JD-9 Mine contains valuable mineral reserves that include, conservatively, over 600,000 <br /> pounds of uranium and millions of pounds of vanadium. See DOE, Final Uranium Leasing <br /> Program Programmatic Environmental Impact Statement(March 2014) ("Leasing PEIS"), at <br /> Table 1.3-1 (estimating 630,000 pounds of uranium oxide in JD-9 lease tract); Findings of <br /> Fact, Conclusions of Law, and Order, In the Matter of Cotter Corporation (N.S.L.)'s Notices <br /> of Temporary Cessation (May 7, 2013), at¶ 57 ("[v]aluable mineral reserves" remain in the <br /> JD-9 Mine); letter, dated July 26, 1990, from Cotter, to the Division, at 3 (known economic <br /> reserves remaining in the JD-9 Mine are approximately 143,100 tons with 92,700 tons of <br /> additional reserves expected to be encountered). Cotter's mine plan for mining such reserves <br /> is attached as Exhibit D to the JD-9 Application Amendment, and projects a life-of-mine <br /> exceeding six years. JD-9 Application Amendment, Exhibit D, at D-2. <br /> Cotter is committed to mining operations at the JD-9 Mine by the end of the second five-year <br /> period of temporary cessation (December 15, 2022). This commitment is demonstrated by <br /> the substantial resources it invested in preparing the JD-9 Mine's EPP, Drainage Design <br /> Plan, mine plan, reclamation plan and other studies; collecting geologic and environmental <br /> data; submitting the JD-9 Application Amendment to the Division; and obtaining the <br /> Division's approval of the JD-9 Application Amendment through the Division's rigorous <br /> adequacy review process. Cotter's commitment is also demonstrated by the ten-year lease, <br /> 2 <br />