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federal funds available this year to create a strategic uranium reserve, as was <br /> proposed by the Trump administration in February 2020. <br /> PRM has therefore elected to conserve its capital resources until such time that the <br /> pandemic is under control, the economy has recovered to some extent, and uranium <br /> and/or vanadium prices allow for economic operation of the SMC. <br /> PRM had also planned to complete the reclamation of the Carnation portal area this fall, <br /> but has decided to delay that reclamation until the fall of 2021 because of technical <br /> reasons. In our proposed 2020 updated Plan of Operations (POO) that was submitted to <br /> the Bureau of Land Management (BLM) in early May of this year, PRM proposed to <br /> establish revegetation test plots on the Carnation waste rock areas and conduct <br /> radiological monitoring and modeling to insure that a person camping on the reclaimed <br /> site for 14 days would receive a standard gamma dose of 15 millirem or less above <br /> background. The test plots are considered necessary because there is very little <br /> stockpiled topsoil at these mines and alternate growth media will need to be developed. <br /> And, although the voluntary 15 millirem threshold has been approved by the BLM at two <br /> Utah mines in the last few years, PRM would like to see the permitting process proceed <br /> further with the BLM before implementing the proposed reclamation program. PRM is <br /> currently in the process of responding to the BLM's review comments on the POO and <br /> its initial request for additional information. <br /> It is our understanding that the Colorado Division of Reclamation, Mining and Safety <br /> (DRMS) considers the current reclamation bonds to be adequate, as they were recently <br /> updated in 2018. We anticipate that the DRMS and BLM will conduct inspections of the <br /> SMC as part of temporary cessation (COVID-19 restrictions permitting) and PRM will <br /> address any concerns that the agencies may have. PRM will have equipment on site in <br /> October to complete any maintenance on the stormwater controls or other facilities that <br /> may be needed. As part of its review of the SMC POO, the BLM requested that PRM <br /> verify that there are no other low-grade stockpiles present on the surface of the portal <br /> areas. A small low-grade stockpile was identified at the St. Jude portal area. The St. <br /> Jude portal will be temporarily reopened in October and the stockpile will be placed in <br /> the decline. <br /> PRM will continue to periodically inspect and maintain the SMC during temporary <br /> closure in accordance with its DRMS permits and the BLM Interim Management Plan <br /> that is provided in Section 7 of the proposed SMC POO. PRM will also work closely with <br /> the DRMS and BLM to reach accord on an appropriate ground water monitoring system <br /> for the complex and to move the Plan of Operations to a point where the National <br /> Environmental Policy Act (NEPA) process can be started. <br /> The SMC will be restarted in a phased manner once vanadium and uranium prices will <br /> allow for economical mining of the deposit. Mining will occur above the water table until <br /> such time that the SMC Hydrogeologic Report is approved and ground water monitoring <br /> systems are determined to be adequate by the DRMS and BLM. <br /> 2 <br />