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Page 2 October 14, 2020 Historical documentation appears incomplete on the warrantee release of all reclamation areas at the mine. However,site inspections show that some areas reclaimed years ago would readily qualify for warranty release and,in fact,may have been released. Documented releases are discussed in Section 2.1. In a DRMS warrantee release letter of January,2006,DRMS stated that areas remaining as not reclaimed and not released are Areas 1, 2, 3, 4, 10, portions of Area 13, and the Soil Barrow Area. The Evaporation Pond and Retort Water Pipeline have not been reclaimed as these facilities are still in use.DRMS stated that the total adjusted remaining acreage for roads was estimated to be 10 acres, including road fill sidecast material areas; and that the total remaining acreage requiring reclamation(affected area)was 38.25 acres,including the Evaporation Pond.Calculations for this submittal indicate a greater unreclaimed acreage of 44.4 acres. Figures 3A and 3B illustrate the current reclamation status of disturbed areas and roads.The reclamation status of previously disturbed areas is discussed below. 1.1 Mine Areas Other than roads and the Evaporation Pond and associated Retort Water Pipeline,the Lower Bench is the only remaining mine area(Area 1)that is not reclaimed.This area consists of 2.1 acres and is currently being used as a mine access staging area to monitor general mine site conditions, hydrological stations, and revegetation progress at other parts of the mine property.A weather station has also been deployed on the Lower Bench. 1.2 Roads 1.2.1 Area 18: Logan Wash Access Road Disturbed acreage associated with the Logan Wash Road or the "tramroad"was originally shown in the mine permit to be 53.4 acres.This road extends from its intersection with Road 45 up Logan Wash to and beyond the mine property. U.S. Bureau of Land Management(BLM)records indicate that the original Logan Wash Road right-of-way(COC-223027)was 58.6 acres and includes all of the Upper Access Road up to the BLM-OOSI property boundary near the intersection of the Upper and Lower Bench Roads.However,the OOSI reclamation plan included the Upper Access Road in Area 13,Miscellaneous Access Roads. In the early 1980's,a number of road realignments,turn-outs,or cut and fill areas were constructed along Logan Wash Road and these areas were included in revised versions of the mine permit. These areas are shown as "B- 1 through B-10"in Table 1.The areas were used for traffic management,and storage of stormwater sediment or road grading or berm materials.The estimated acreage disturbance for these areas was approximately 6.0 acres. All of these segments, except B2,B3, B5,B5A,B7, and B8 were released in 1986. The remaining areas have either been reclaimed or incorporated into current road use and maintenance. (Note that a release request in 1986 refers to a B 12 area. Maps show that this area was associated with previously reclaimed and released access roads). Reclamation of the main Logan Wash Road is not planned as this road is used by the public and for energy industry access. The Upper Access Road extends from the main Logan Wash Road to the Research Mine and beyond to the intersection with the Upper Bench Road and Lower Bench Road; it is estimated to consist of 4.8 acres. The Upper Access Road will be reclaimed at the appropriate time after mine monitoring ceases(unless it is decided that this road remain in place to support monitoring of the Penstemon debilis (P. debilis, aka Parachute penstemon]),a listed threatened species).Currently,the road is being used to access the mine site,primarily the Lower Bench. OOSI is requesting that Areas B2,B3,B5,B5A,B7 and B8,an estimated total acreage of one acre,be released of warranty as they have revegetated completely.Areas B2 and B8 are shown in Figure 4,Area B3 is shown in Figure 5,Area B5 is shown in Figure 6,Area B5A is shown in Figure 7,and Area B7 is shown in Figure 8. AYeldel I_10142020.docx