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DRMS Comment Text(from DRMS letter AR Round 2) OSMI Responses Comment# The letter provided under Exhibit S from Ouray County regarding the end use of the structures to remain contains a.As noted in the letter from Ouray County dated May 24,2022,OSMI will be required to maintain and is inspection and maintenance requirements as well as potential permitting requirements for an alternative use. committed to maintaining buildings remaining on site post-reclamation so that they do not become an attractive a. Please provide a commitment to inspect and maintain all buildings that are to remain onsite post-nuisance or a hazard to the public.This includes the admin building. reclamation b.After discussions with the Ouray County Board of County Commissioners and the Ouray County Planning and b. It is noted that Ouray County will require a Certificate of Occupancy(CO)for use of the Admin Building Land Use Department,we learned that the original,completed portion of the Admin Building(otherwise referred post reclamation.Please secure and provide the Division the approved CO for the Admin Building.Until the CO is to as the Dry Building)did receive what's referred to as a Certificate of Completion(A Certificate of Occupancy is provided,the Division will bond for the removal of the Admin Building. If the Admin Building is to be removed issued for dwellings under current county land use code and therefore would not be required for the buildings to 18 please update all maps,tables and exhibits accordingly. remain on the mine site). For the portion of the Admin Building that is currently under construction,OSMI has reached agreement with the County that it will continue to make substantial progress towards completing construction on the structure and will partake in the required inspection process needed to obtain a Certificate of Completion once construction is complete.Until that time,the addition to the Admin Building will be treated the same as the other buildings discussed in the May 24,2022 letter and may remain on site post-reclamation.See letter from Ouray County dated September 6,2022 and see attached CO issued forthe Admin building,which are provided in Attachment 4. Section 3.1 states that"the final slope of the(Revenue)TSF will be 3H:1V,where practical.If needed,the final Comment noted.The Revenue TSF will be constructed with 3H:1V slopes.If there is a need to move to a 2H:1V slope configuration for the Revenue TSF may be a maximum of 2H: 1V."The Division acknowledges that the slope,OSMI will notify the Division in writing of such a change prior to construction.As noted in Section 3.1,OSMI Geotechnical Data provided supports the final slope configuration being 2H: 1V. However all submitted maps, has already committed to providing additional analysis should it propose a 2H:1V slope for the Atlas TSF. 19 narratives, etc. primarily reference the 3H:1V slopes being utilized. If OSMI wishes to utilize the 2H:1V slope configuration at the Revenue TSF at a later date,please notify the in writing Division prior to construction.Until such notification is made,3H:1V slopes shall be implemented.Please note that deviations from 3H:1V slopes at the Atlas TSF,will require additional certifications and analysis. Please revise the table in Section 3.4,page E-7 to show the volume of waste rock to place underground for each Approximately 2,222 CY of waste rock is required to backfill the three UG storage portals.Section 3.4 has been 20 portal location.If no waste rock will be placed in the underground workings,please revise the table to omit that updated to reflect this amount.Exhibit L Reclamation Task 2A was updated to reflect the updated amount for the statement.Volumes provided in Exhibit E should match the volumes in Exhibit L. 3 UG storage portals. 21 For all areas receiving topsoil and revegetation reclamation treatment,please commit to decompaction of those OSMI commits to decompaction(i.e.,ripping)the areas that are to receive topsoil and revegetation prior to areas prior to topsoil application. topsoil application.Section 4 of Exhibit E has been updated to reflect this commitment. Volumes are provided in Exhibit L for grading to achieve the applicable post reclamation topography however the Section 4 of Exhibit E was updated to include the total volume of material to be graded at the Revenue permit narrative does not include this information.Please revise Section 4 of Exhibit E to include the total volume of base area to reach final grade.Section 3.2 also was updated to include an estimate of material that will be used to 22 material to be moved to achieve the post reclamation topography prior to topsoil application.This information cover the reclaimed borehole in Governor Basin.A volume of 1.44 cubic yards of crushed rock was calculated should also specify what volumes are associated with the reclamation of the Governors Basin Raise Bore area. based on 10'diameter area at 6 inch depth.This material will be used as the final 6"cap over the steel plate/ concrete pad that will secure the shaft opening.This material is included in Task 03B in Exhibit L. Section 4 of the narrative of Exhibit E does not address the requirements of Rules 3.1.9 and 6.4.5(2)(d)describing Section 4 of Exhibit E has been updated to address topsoil preservation requirements.Section 4.4 of Exhibit D has topsoil preservation.The PAR table responses#38 states"The topsoil stored on site in the stockpile will be seeded been updated to be consistent with the topsoil importation stated in Exhibit E. in spring of 2022 and will be protected by a vegetative cover to prevent erosion. Imported topsoil will not be brought on site until it is needed for reclamation and will be directly hauled to the site as reclamation is 23 occurring."This response should be incorporated into section 4 of Exhibit E.Note that Page D-20,section 4.4 of the mine plan contradicts this statement by stating"topsoil will be imported over the life of the mine...",as does Exhibit I.Please revise all exhibits to consistently reflect topsoil importation timing. Please specify the number of acres to receive hydromulch application and the number of acres to receive hand Exhibit L specifies hydromulching of at least 1 acre of reclaimed area if there are instances where equipment 24 mulch. access is limited.Although this technique is accounted for in Exhibit L,Reclamation Costs,we don't expect to use it. Amendment 02 AR Responses Round 2 M-2012-032 3of8