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Letter to Richard Blubaugh 2 July 22, 2008 <br />Centennial Proiect, Receipt of NOI File No. P-2008-043 <br />You have placed the details of the proposed ground water monitoring wells in the confidential section of the <br />NOI. Please provide your reasoning and rationale, in terms of SB-228, for excluding this information from <br />the public record. The DRMS is sending you a review of the NOI's confidential portions under separate <br />cover. That review will not be placed in the public record at this time, but depending on your rationale <br />relative to confidentially of the monitoring wells, portions of the DRMS separate review maybe placed into <br />the public record at a future date. In accordance with SB-228, you will be notified in advance of information <br />DRMS intends to transfer from the confidential file into the public record, and have the opportunity to appeal <br />the DRMS determination to the Mined Land Reclamation Board prior to the transfer. <br />Section III, item 3 of the NOI states that approximately 52.2 cubic yards of earth will be moved in the <br />conduct of the proposed prospecting. DRMS has estimated that 170 bank cubic yards of material will be <br />excavated from the proposed mud pits based on the mud pit sizing information provided in section III, item 6 <br />of the NOI. The 170 cubic yard amount was used by DRMS in estimating earth moving costs for <br />reclamation. Please provide an explanation of the derivation of the 52.5 cubic yard amount or agree to the <br />larger amount determined by DRMS. <br />The NOI proposes to seal the upper portions of the holes using bentonite chips. In accordance with rule <br />5.4.2(5), the DRMS will instead require that the upper ten feet of each hole be filled with Portland cement <br />grout. Since the lands to be drilled at least have the potential to be cropped, DRMS will require that any <br />casing be cut off and removed and that the top of the cement plugs be completed three feet below ground <br />surface, with the upper three feet backfilled with native soil and mounded. DRMS has incorporated the <br />cement plugging into the estimated reclamation costs. <br />DRMS requires that Powertech commit to the following procedure and requirement for this NOI: <br />The surface of the backfilled mud pits will not exceed the following limits: <br />1. The concentration of radium-226 or radium-228 in soil may not exceed the background level by more <br />than 5 picocuries per gram (pCi/g) or 0.185 becquerels per gram (Bq/g), averaged over the first 15 <br />centimeters (cm) of soil below the surface; and <br />2. The concentration of natural uranium in soil, with no radioactive decay products present may not <br />exceed the background level by more than 30 pCi/g or 1.11 Bq/g, averaged over the top 15 cm of soil <br />below the surface; and 150 pCi/g or 5.55 Bq/g, average concentration at depths greater than 15 cm <br />below the surface, so that no individual member of the public will receive an effective dose equivalent <br />in excess of 100 mrem per year or 1 millisievert (mSv) per year. <br />The DRMS will require test results demonstrating that these limits have not been exceeded; the tests are to be <br />conducted during or immediately following the reclamation of the mud pits. If these limits are exceeded, <br />DRMS may require appropriate off site disposal of mud pit contents. <br />DRMS has estimated the costs to reclaim your proposed prospecting disturbances, including plugging and <br />abandonment of all drill holes, at $55,000.00 (see enclosed reclamation cost estimate). Bond in this amount <br />must be provided. Prospecting bond forms are available online at <br />http://minim.state.co.uslProspectingForms htm. You may not commence prospecting operations until the <br />