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2018-02-16_ENFORCEMENT - M1977311
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2018-02-16_ENFORCEMENT - M1977311
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Entry Properties
Last modified
2/16/2018 11:41:58 AM
Creation date
2/16/2018 11:09:17 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977311
IBM Index Class Name
Enforcement
Doc Date
2/16/2018
Doc Name Note
Objectors' Response to Cotter's Motion on Burden of Proof
Doc Name
Objectors' Response to Cotter's Motion on Burden of Proof
From
INFORM
To
MLRB
Email Name
CMM
LJW
GRM
Media Type
D
Archive
No
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Ilk <br />11 <br />cotter <br />The associated stormwater management controls will be inspected and maintained as <br />necessary to provide control of stormwater run off as described in the Environmental <br />Protection Plan EPP for the JD 6 Mine dated September 2012 attached as Exhibit T to <br />Cotter s 110d Application Amendment Application Amendment for the JD 6 Mine dated <br />September 2012 The EPP and Application Amendment also contain the measures to be <br />taken to comply with reclamation requirements and or other activities related to the <br />performance standards of Section 3 1 of the Hard Rock Metal Mining Rules which will <br />continue to be implemented during periods of temporary cessation and are incorporated by <br />reference into this letter <br />The existing financial warranty of 46 100 00 held by the Division and the United States <br />Department of Energy DOE is adequate to cover the reclamation liability of the site as it <br />exists today 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 re contouring the mine waste material <br />and closing the two vent holes The affected area has not reached the permitted acreage yet <br />consequently the mine waste material that would need to be re contoured is less than the <br />amount used for the bond calculation Following the re contouring effort the currently <br />stockpiled topsoil would be spread over the existing affected acreage This area would then <br />need to be seeded to promote re vegetation of the site <br />The JD 6 Mine contains valuable mineral reserves that include conservatively hundreds of <br />thousands of pounds of uranium and over one million pounds of vanadium See DOE Final <br />Uranium Leasing Program Programmatic Environmental Impact Statement March 2014 <br />Leasing PEIS at Table 1 3 1 estimating 850 000 pounds of uranium oxide in JD 6 lease <br />tract Findings of Fact Conclusions of Law and Order In the Matter of Cotter Corporation <br />N S L s Notices of Temporary Cessation May 7 2013 at 57 v aluable mineral <br />reserves remain in the JD 6 Mine letter dated March 20 1990 from Cotter to the <br />Division at 3 known economic reserves remaining in the JD 6 Mine are approximately <br />59 500 tons with 36 300 tons of additional reserves expected to be encountered Cotter s <br />mine plan for mining such reserves is attached as Exhibit C to the JD 6 Application <br />Amendment and projects ore production ranging from 50 to 100 tons per day JD 6 <br />Application Amendment Exhibit C at C 1 <br />Cotter is committed to mining operations at the JD 6 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 6 Mine s EPP Drainage Design <br />Plan mine plan reclamation plan and other studies collecting geologic and environmental <br />data submitting the JD 6 Application Amendment to the Division and obtaining the <br />2
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